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Impact Assessments (22397/19)

Request

1) please can you send me a copy of the current subject access request acknowledgment AND response letter that you use

2) a copy of the last 5 dpias completed

3) a copy of any internal mandatory information governance training that you give to staff which was written in the last 2 years including presentation slides and videos and any other media

4) a copy of any instructions given to staff members to reduce data security breaches, for example double checking work

5) a copy of any policies implemented in the last 2 years within the organisation to help reduce the environmental impact that the organisation has?

6) please can I have a copy of the risk rating that you use to evaluate data security incidents?

Response

We can confirm that relevant information is held by West Midlands Police. Whilst the majority of the information is attached, I am not required to release all of the information requested.

Part of this information has already been released into the public domain, and under Section 21 of the Act, we are not required to provide this information if it is already reasonably accessible to you. Links for these will be provided in the attached document (22397_Attachment).

REASONS FOR DECISION

With regard to the remainder of your request, the redacted information is exempt by virtue of the following exemptions:

Section 31(1)(a) – Law enforcement

Section 40(2) – Personal information

These exemptions and explanatory notes are shown here:

https://www.app.college.police.uk/app-content/information-management/freedom-of-information/#freedom-of-information-exemptions

In line with the above, I am required to complete a Prejudice Test/Public Interest Test (PIT) on disclosure. Please find this PIT attached (22397_PIT).

Section 40(2) is an absolute and class based exemption if to release the information exists would breach the third party’s data protection rights.  In this case to release this personal information would not constitute fair processing of the data. As this exemption is class based I am not required to identify the harm in disclosure and in this instance I believe that the right to privacy outweighs any public interest in release.

Attachments

22397_Attachment

22397_PIT

DPIA_BWV_Stage_1_Form_V0_1

DPIA_Stage_1_Corevet_v0.1

DPIA_Stage_1_Form_DAL_2019_0012_v2

DPIA_Stage_1_Form_Gazetteer_V0_1

SA_Force_Positive_letter_1.pdf

Subject_Access_Acknowledgement.pdf