Dear Sir or Madam,

In 2006, in response to a Freedom of Information request by another
party regarding data stored in Abbey's microfiche system in
relation to the Data Protection Act, your office stated an intent
to visit Abbey, and other banks or organisations, to gain better
understanding of how non-electronic records were held.

I would like to enquire as to whether any such visits took place,
whether within or without the banking sector, and if so, that you
release copies of any reports, memos, notes, correspondence or any
other such material discussing the findings of such visits.

Yours faithfully,

Richard

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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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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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
[ICO request email]

Yours sincerely

Angela Ellison

Assistant Internal Compliance Manager

Information Commissioner's Office

01625 545 878

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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

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Dear Angela,

Please send as much as possible by email, and with that provide
details of what material (where possible, with a summary of such)
can only be sent by snail mail.

Thanks,

Richard

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

show quoted sections

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
[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 [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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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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Dear Angela,

Thank you for this information. I would like to receive copies of
the letters referenced; however I have a strong preference that
these be provided in electronic format. I am a little surprised
that you seem to be unable to do so. Presumably even if you do not
have the ability to send a redacted copy of the original electronic
document, you have access to a document scanner and could rescan
the hard-copy versions you would otherwise post out?

Yours sincerely,

Richard

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

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

Dear Angela,

Thank you for providing these letters as a PDF. This provides all
the information I was seeking.

Yours sincerely,

Richard