Those
clever bods over at Allen & Overy
have developed a handy app to remind Data Protection Officers how to deal with
Subject Access Requests. First released in May 2012, I must admit that I’ve
only just seen it.
It
makes a change from having to refer to 10 separate ICO publications that touch
on particular aspects of Subject Access Requests. If you didn’t realise that
there were 10 separate guidance documents, take a squint at A&O’s reference
materials. Some of the hyperlinks to materials on the ICO’s website are
currently broken – but a decent internet search engine should be able to locate
the original documents eventually. Perhaps, in the fullness of time, an ICO archivist will
develop a list of “live” and “withdrawn” guidance notes, to avoid too much
confusion amongst the privacy anoraks, for whom guidance from the ICO is as greatly
revered as an original copy of the Magna Carta. But I do appreciate that, given
the current financial constraints, such a task is well down the ICO's priority list.
As
well as bite size summaries of relevant ICO advice, the AccessAssist app includes an
interactive Q&A-based tool, an analysis of the usual exemptions, frequently
asked questions, links to support materials and subject access fee tables.
Having
used the app for a few minutes, I can see its potential to comprise a key item in a DPO’s
toolbag. Any decent DPO needs some props to reassure their clients that
they’ve got all the tools of the trade. I usually carry an original copy of the
Data Protection Act, carefully annotated with notes and comments made by a key
civil servant that was responsible for implementing it. And a tatty copy of an old ICO data protection guide.
From
now on, when I’m advising on tricky Subject Access Requests, I’ll make sure
that the client sees me using this reference tool, too – which ought to provide
sufficient assurance that I both know my stuff and am completely up to date
with the very latest legal thinking.
The
best bit – particularly for hard pressed public sector information rights folk
– is that the app is free. All you need is an iPad. It's not
yet available for the iPhone, and I’ve no idea whether there are plans to
develop a version specifically for the small screen.
The
app has also been scrutinised by the ICO. According to Deputy Commissioner and Director of Data Protection David Smith, “we congratulate Allen & Overy on the development of this app.
The right of subject access is at the heart of the Data Protection Act. Any
tool that makes it easier for businesses to understand and meet their
obligations to those individuals they hold information about can only be
welcomed.”
Download
it and let me know what you think.
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