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 Perhaps, in the fullness of time, an ICO archivist will develop a list of “live” and “withdrawn” guidance notes, to avoid too much confusion amongst the privacy anoraks, for whom guidance from the ICO is as greatly revered as an original copy of the Magna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.