OSC Report

Actions required

Current Status

Date for completion

8.1 & 8.2

Central Register

Central Number

System

Change to an electronic register including the columns listed below.

Operational Name

Name of Surveillance Subject

Purpose of the Surveillance

Document type (Auth/Cancel/Review)

Urgency - Yes/No

Confidential - Yes/No

Start Date

Review Date 1 and 2

Cancellation

Department

Authorising Officer

Refusal

Chief Executive's Reference number

Checks to be in place

· P. Hoult. to email A.O.'s the C. Exec.'s allocated reference number.

· Always have an operational name.

· Check progress regularly - critical dates.

· Email reminders to A.O.'s when necessary.

· Print Spreadsheet quarterly.

· Monitoring Officer to write comments and sign the sheet.

· P. Hoult to file the sheet.

Discussions have taken place with Audit and all the required safeguards have been put in place relating to managing the records - flagging dates and reminders being sent to inboxes. Also security of printed forms has been improved.

To be in place by March 2006.

Completed 02 March 2006.

Completed May 2006.

8.3

Review the overall number of Authorising Officers

Emails to be sent to Departments asking them to consider the necessity of having the current level of Authorising Officers.

Ask the OSC if they wish to comment on the appropriateness of using School Governors as Authorising Officers, or as independent Data Controllers, should schools be responsible for their own Authorisations. The Inspector raised these points with the Council.

Emails to be sent March 2006.

Completed April 2006.

8.4

Review number of copies made and IT Security

The original forms should be kept with the file/A.O. and a copy sent to the Monitoring Officer.

Copy should be available to the surveillance officer as and when necessary.

Authorisation to access mail in-boxes, via IT, must be cancelled promptly, as soon as the operation is complete

Audit agreed.

To be agreed with Andrew Slee

Agreed with Audit.

Completed March 2006.

Completed May 2006.

CHIS

· Refresher training required for A.O.'s on providing more details about risk assessment, proportionality and collateral intrusion content within the forms. These areas have not always been sufficiently evidenced.

· The safety and welfare of the CHIS and their identity should be protected and not detailed unnecessarily in documentation.

Training to be completed June/July 2006. Meeting arranged (16/03/06) with Andrew Slee to identify any changes and actions required in order to comply with the Act.

Date set for Training 07 July 2006.

Updated policies and procedures to be in place by 30 June 2006.

Comments made by the Inspector on the day

· More details must be provided within the Forms, clearly identifying how proportionality, and collateral intrusion have been considered.

· Review dates must be set when the Authorisation/Renewal is signed .

· Cancellations must be made on time.

· Systems should be in place to check critical dates.

· Directed Surveillance - only one application is necessary for each operation. Emergency or planned CHIS applications forming part of the same operation can be added to the original authorisation at a later date if the application form states this may be necessary in the future.

· It is recommended that changes are made to HCC Forms to reflect the updated Forms now available on the OSC website.

Our policy guidance will be updated following agreement with Andrew Slee on the practical implications.

All comments have been taken into consideration as part of our updated procedures.

Report to Governance Committee

Following the inspection report of the OSC Inspector a report will be taken to members of the Governance Committee highlighting the recommendations of the OSC. Members will be updated on the actions taken by the Council and changes made to our policy and procedures in order to ensure full compliance with the legislation.

May 2006

June 2006.