Research visits re: non-electronic records

Our reference: FOI/1015

Dear Mr Jackson

Thank you for your email dated 29 July 2008.

Your request is being dealt with in accordance with the Freedom of
Information Act 2000. We will send our response to you by 27 August 2008
which is 20 working days from the day after we received your request.

Yours sincerely

Angela Ellison

Assistant Internal Compliance Manager

Information Commissioner's Office

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[1]http://www.ico.gov.uk or e-mail: [email address]

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF

Tel: 01625 545 700 Fax: 01625 524 510

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Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. http://www.ico.gov.uk/

Our reference: FOI/1015

Dear Mr Jackson

We are currently in the process of compiling the information for our
response to your request.

However, some of the information is not held electronically. Therefore,
could you let us have your postal address so that we can send you hard
copies of the information which is held in only manual files.

Please could you send your response to this email to
[1][ICO request email]

Yours sincerely

Angela Ellison

Assistant Internal Compliance Manager

Information Commissioner's Office

01625 545 878

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[2]http://www.ico.gov.uk or e-mail: [email address]

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF

Tel: 01625 545 700 Fax: 01625 524 510

show quoted sections

Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. mailto:[ICO request email]
2. http://www.ico.gov.uk/

I am out of the office until Monday 1st September. If your email needs a response before then, please could you forward it to [ICO request email]
Many thanks.
Angela

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http://www.ico.gov.uk or e-mail: [email address]
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 01625 545 700 Fax: 01625 524 510

show quoted sections

Our reference: FOI/1015

Dear Mr Jackson

Thank you for your email dated 27 August 2008.

In your request you referred to the fact that in 2006 the Information
Commissioner's Office (ICO) stated an intent to visit Abbey and other
banks or organisations to gain a better understanding of how
non-electronic records were held. You asked whether such visits took
place, within or without the banking sector and, if so, for copies of any
material which discussed the findings of such visits.

I can confirm that subsequently visits were made to three organisations -
Abbey, Barclaycard and Lloyds TSB. These visits were considered necessary
because at the time the banks were failing to respond to a large number of
subject access requests which individuals were making for information held
in microfiche. Thus the meetings were not solely focused on
non-electronic records, but rather the banks' overall capacity to meet
their subject access obligations.

No reports were made of these meetings, although because they were
arranged as a consequence of the large number of complaints that were
received by the ICO about the banks at that time, there is correspondence
within individual complaint cases which refers to them.

However whilst these letters refer to the meetings they do not discuss the
ICO's findings. Our findings were set out in letters which were sent to
each of the banks following the visits. We have prepared hard copies of
these letters to send to you in response to your request, as we have
redacted information within them which comprises personal details of
members of staff at those organisations. This information is the
`personal data' of those individuals, and we consider that its disclosure
in this context would be `unfair' in data protection terms and, thus, in
contravention of the first Data Protection principle. Under section 40(2)
of the Freedom of Information Act 2000 information can be withheld from a
response to a request under the Freedom of Information Act 2000 if the
disclosure of the information would contravene one of the Data Protection
principles, as in this case.

We can send you the copies of these letters if you could let us have your
postal address. In the meantime, however, I am attaching a document which
was drafted by the Assistant Commissioner, Philip Jones, following the
visits to the banks. This is entitled `Microfiche and Microfilm
Systems'. It was drafted in May 2007 but was not subsequently finalised
or released because the decision was taken to incorporate it in the, as
yet, unreleased guidance on `relevant filing systems'. However it refers
to the visits to the banks and sets out the ICO's view following those
visits.

If you require copies of the letters referred to above, please could you
let us have your postal address. Otherwise, I hope that this provides you
with the information you require. However, if you are dissatisfied with
this response and wish to request a review or make a complaint about how
your request has been handled you should write to the Internal Compliance
Team at the address below or e-mail
[1][email address]

Your request for internal review should be submitted to us within 40 days
of your receipt of this response. Any such request received after this
time will only be considered at the discretion of the Commissioner.

If having exhausted the review process you are not content that your
request or review has been dealt with correctly, you have a further right
of appeal to this office in our capacity as the statutory complaint
handler under the legislation. To make such an application, please write
to the Senior Complaints Resolution Manager, Complaints Resolution Team at
the address below or e-mail [2][email address].

A copy of our review procedure is also attached.

Yours sincerely

Angela Ellison

Assistant Internal Compliance Manager

Information Commissioner's Office

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[3]http://www.ico.gov.uk or e-mail: [email address]

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF

Tel: 01625 545 700 Fax: 01625 524 510

show quoted sections

Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. mailto:[email address]
2. mailto:[email address]
3. http://www.ico.gov.uk/

FOI/1015

Dear Mr Jackson

Thank you for your email dated 1 September 2008 indicating that you would
like to receive copies of the letters which were sent to the banks, in
electronic format.

We have scanned them into a PDF file which is attached herewith. With
regard to these letters I would point out that there were two meetings
with Barclaycard, and thus there are two letters which were sent to that
organisation, one following each meeting. You will note also that the
first letter to Barclaycard is a draft letter. We have been unable to
locate a copy of the actual letter that was sent out, although it would
seem likely this copy was the final draft.

Also, the large redacted areas of the letter to Lloyds TSB relate to an
individual's complaint about other information held about him by the
Bank. As such, this information does not come under the scope of your
request.

I hope that this provides you with the information you require.

Yours sincerely

Angela Ellison

Assistant Internal Compliance Manager

Information Commissioner's Office

show quoted sections

[1]http://www.ico.gov.uk or e-mail: [email address]

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF

Tel: 01625 545 700 Fax: 01625 524 510

show quoted sections

Communications via the GSi may be automatically logged, monitored and/or
recorded for legal purposes.

References

Visible links
1. http://www.ico.gov.uk/