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Dear Oxfordshire Fire and Rescue Service,

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?

Yours faithfully,

tim wells

FOI - E&E, Oxfordshire Fire and Rescue Service

1 Attachment

Our reference: 16268 FOI

Dear Mr Wells,

Thank you for your correspondence received on 07 January 2020 in which you
asked for the following information:

 

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?

 

 

Your request is being considered and you will receive the information
requested as soon as possible and in any event within the next 20 working
days in compliance with the Environmental Information Regulations
2004/Freedom of Information Act 2000, unless an exception applies. This
means that the council will respond to you by 04 February 2020 at the
latest.

 

If appropriate, the information requested can be made available in
alternative formats, including other languages, Braille, large print, and
audiocassette. If you require any of these formats then please let me
know.

 

Please contact me if you have any have further enquiries about your
request. I would be grateful if you could quote the reference number given
at the top of this email.

 

Kind regards

Renata Malinowski

 

Freedom of Information Support Officer

Joint Commissioning and E&E

Email: [1]E&[email address] and
[2][email address]

 

 

[3]cid:image002.jpg@01D072CF.0B31BC70

 

 

Save money and paper - do you really need to print this email.

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [4]http://www.oxfordshire.gov.uk/emaildiscl....

 

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [5]email disclaimer. For information about how
Oxfordshire County Council manages your personal information please see
our [6]Privacy Notice.

References

Visible links
1. mailto:E&[email address]
2. mailto:[email address]
4. https://webmail.tiscali.co.uk/cp/ps/Mail...
5. http://www.oxfordshire.gov.uk/emaildiscl...
6. https://www2.oxfordshire.gov.uk/cms/site...

FOI Team, Oxfordshire Fire and Rescue Service

6 Attachments

Our reference:  16268 FOI

 

Dear Mr Wells,

 

Thank you for your request of 07 January 2020 in which you asked for
information about data protection arrangements.  Please find our response
to your questions below:

 

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

 

The standard acknowledgement response for subject access requests is:

Request Reference Number: XXXXXX

Thank you for your request.

Where possible we will complete your request within one calendar month. If
further information (e.g. additional identification etc.) is needed the
Council will contact you, but this will mean it may take longer to deal
with your request.

For Subject Access Requests:

The Council can only provide information that it has collected. If you
think another organisation holds any of the information you want you
should make a request directly to them.

The standard response letter is:

 

Please find enclosed a copy of the requested information for yourself in
response to your Subject Access Request. 

 

Your requests for information relate to access to personal data under the
Data Protection Act (“DPA”) 2018 and also third-party information under
the Freedom of Information Act (“FOIA”) 2000. In line with the relevant
legislation, only personal data of individuals who have provided ID and
informed consent has been disclosed.  You may find some papers have spaces
where certain data may have been removed, information about other people
(third party) will have been redacted (removed) as this is not your
personal data.

 

If you are dissatisfied with the information you have received or the
service that we have provided you may make a complaint by emailing
[1][email address]; telephone 01865 815906.

 

If you remain dissatisfied with the handling of your request, you have a
right to appeal to the Information Commissioner at: The Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF. Telephone: 0303 123 1113 Website: [2]www.ico.gov.uk 

 

If we can be of any further help, please do not hesitate to contact me at
the address above.

 

 

 

2) a copy of the last 5 dpias completed

 

The Council does hold this information.  However, on this occasion we are
not able to supply you with the copies of the DPIAs in question as we
believe an exemption applies, in short because we consider that the
information contained within them was supplied in confidence to us.  Our
exemption is set out in full later in this response.

 

However, you may find our template DPIA of use as to how the Council
approaches organisations as regards DPIAs.  Please find this attached (as
‘Template DPIA’).

 

 

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

 

The annual mandatory information governance training is done via an
e-learning course The e-learning comprises of 10 modules. The subjects of
the modules are:

o Introduction
o Data Protection Basics
o Data Protection at OCC
o Security Incidents
o Personal and sensitive information
o Seeing consent
o Sharing personal information
o Privacy by design
o Commissioned services
o Quick reference

 

 

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

The Council has a number of polices to which employees must have regard
when dealing with data. The following polices cover security incidents:

 

o Acceptable Use Policy
o Data Protection Policy
o Data Sharing Policy
o Email Policy

 

Please see these four documents, attached.  The Council also issues
periodic Intranet articles to staff about this.  An example of this is
attached as “Stop, Think, Check’.

           

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?

 

Oxfordshire County Council does not have a single, overarching, statutory
responsibility for the natural environment in the same way that it does,
for example, with highways.

 

In respect of development reference is often made to the policies within
the relevant district council’s Local Plan, supported with national policy
and guidance notably the NPPF 2019.

 

There are however OCC-relevant environmental policies, tools and guidance
distributed across a range of statutory and non-statutory documents and
sources.  Notable amongst these are:

 

Minerals and Waste Core Strategy can be found via the following link:
https://www.oxfordshire.gov.uk/residents...

 

As minerals planning authority OCC has an adopted, statutory core strategy
Part 1 dating from September 2017.  This includes core policies on

 

Sustainable development C1
Climate change C2
Flooding C3
Water environment C4
Local environment, amenity and economy C5
Agricultural land and soils C6
Biodiversity and geodiversity C7
Landscape C8
Restoration of Mineral Workings M10

 

 

Connecting Oxfordshire LTP 2015-2031

 

The local transport plan recognises the importance of the natural
environment and includes policies

 

“Policy 24 Oxfordshire County Council will seek to avoid negative
environmental impacts of transport and where possible provide
environmental improvements, particularly in Areas of Outstanding Natural
Beauty, Conservation Areas and other areas of high environmental
importance.” Page 74 please see link below.

 

“Policy 25 Oxfordshire County Council will work with partners to improve
public spaces and de-clutter the street environment.” Page 74 please see
link below.

 

“Policy 27 Oxfordshire County Council will support appropriate
opportunities for improving towpaths along the waterways network, where it
would not harm the ecological value of the area or waterway network.” 
Please 78 please see link below.

 

[3]https://m.oxfordshire.gov.uk/cms/sites/d...

 

 

Biodiversity

 

The policy environment around biodiversity has developed rapidly over
recent years.  A forthcoming Environment Bill is likely to bring still
further important developments notably on mandatory biodiversity net gain
and conservation covenants.

 

Oxfordshire specific guidance, not adopted policy, is contained within
several documents including

 

Biodiversity and Planning in Oxfordshire 2014

[4]https://www2.oxfordshire.gov.uk/cms/site...

 

The Oxfordshire Wildlife and Landscape Study (OWLS), which combines
landscape and biodiversity

[5]http://owls.oxfordshire.gov.uk/wps/wcm/c...

 

In particular attention is drawn to the county’s Conservation Target
Areas.  These are the county-level priority areas for investment in and
enhancement of biodiversity.  They are well referenced across the suite of
policy documents at district level and the M&W core strategy.  Details on
individual CTAs can be found here:

[6]https://www.wildoxfordshire.org.uk/biodi...

 

Work is currently underway to identify a county-level nature recovery
network which may ultimately link to national policy via the NPPF.  This
is currently in draft and builds on the CTAs.

 

AONBs

 

The three AONBs in Oxfordshire – the Chilterns, Cotswolds and North Wessex
Downs - are of national significance.  They are strongly referenced in OCC
policy and associated documents.  Each AONB has recently updated its
Management Plan which provides a range of relevant policies, supported by
additional technical guidance.  OCC has a statutory duty of regard to the
purposes of the AONB designation and the AONB policies are a material
consideration in planning.

 

Climate

 

OCC’s recently published Climate Action for a Thriving Oxfordshire
declaration (OCC, 2019) includes reference to “Manage land to capture
carbon”.

 

[7]https://news.oxfordshire.gov.uk/county-c...

 

 

Trees

 

OCC policies for tree management and maintenance works on county council
properties and the public highway network are set out in a similarly
titled document, reference CMDE8, 2013 v1.1

 

[8]https://m.oxfordshire.gov.uk/cms/sites/d...

 

 

Roadside Verges

 

Roadside verges which can be important for biodiversity and landscape. 
The OCC Draft Grass Cutting Policy 2018 included reference to the
management of verges for biodiversity and landscape (reference needs
updating!)

 

[9]https://www.oxfordshire.gov.uk/sites/def...

 

 

 

Flooding and Water Resources

 

The OCC Oxfordshire Local Flood Risk Management Strategy includes a number
of objectives and policies that note the links between water management
and the natural environment and the gains that can come from considering
both together.

 

[10]https://www.oxfordshirefloodtoolkit.com/...

 

 

OCC’s Local Standards and Guidance for Surface Water Drainage on Major
Development in Oxfordshire (v1. Nov 2018) contains useful guidance on how
sustainable drainage and natural environment enhancement can work
together.

 

[11]https://www.oxfordshirefloodtoolkit.com/...

 

 

Public Health

 

The Oxfordshire Joint Health and Wellbeing Strategy (2018 – 2023) provides
a framework in which high quality places can help improve people’s health
and wellbeing.

 

[12]https://www.adderburypc.co.uk/securedocs...

 

 

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

There are no standard risk ratings for data security incidents.

 

What follows is the legal rationale for the exemption under Question 2
above (DPIAs).   

 

The Council considers that the information in the DPIAs has been supplied
to us in confidence by the organisations in question and describes in some
detail various aspects of the business, risks and mitigations within the
DPIA context.

 

As such, we consider that the information is exempt from disclosure by
virtue of the exemption contained in Section 41 of the Freedom of
Information Act 2000. Section 41 provides that information is exempt
information if— .

(a) it was obtained by the public authority from any other person
(including another public authority), and .

(b) the disclosure of the information to the public (otherwise than under
this Act) by the public authority holding it would constitute a breach of
confidence actionable by that or any other person.

 

In answering questions within the template DPIA, organisations provide
detailed information about their business and planned actions and risk
mitigations.  As such part (a) of the exemption is satisfied. When
considering section 41(2), and considering whether there is an actionable
breach of confidence it necessary to consider what gives rise to an
actionable breach. In this case the information supplied has the necessary
quality of confidence.  It is therefore subject to the obligation of
confidence (in that we have no consent to disclose this to you) and
unauthorised disclosure would result in detriment to the organisations
concerned. In light of this, the Council has decided not to release this
information to you and given this is an absolute exemption, no public
interest test is required.

 

In all other respects, we hope the information supplied is useful to you.

 

Internal review

If you are dissatisfied with the service or response to your request, you
can ask for an internal review as follows:

 

o Contact the Freedom of Information team in Law & Governance:

[13][email address

o Write to the Freedom of Information team at the FREEPOST address:

 

Freedom of Information Team
Oxfordshire County Council
FREEPOST (RTLL-ECKS-GLUA)
Oxford OX1 1YA

 

If you remain dissatisfied with the handling of your request or complaint,
you have a right to appeal to the Information Commissioner at:

 

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

Telephone: 0303 123 1113 Website:  [14]https://ico.org.uk

 

Please let me know if you have further enquiries. I would be grateful if
you could use the reference number given at the top of this email.

 

Yours sincerely,

 

Caroline Parker

ICT Information Services Manager

Oxfordshire County Council

Email:  [15][email address]

[16]www.oxfordshire.gov.uk

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [17]http://www.oxfordshire.gov.uk/emaildiscl....

 

 

This email, including attachments, may contain confidential information.
If you have received it in error, please notify the sender by reply and
delete it immediately. Views expressed by the sender may not be those of
Oxfordshire County Council. Council emails are subject to the Freedom of
Information Act 2000. [18]email disclaimer. For information about how
Oxfordshire County Council manages your personal information please see
our [19]Privacy Notice.

References

Visible links
1. mailto:[email address]
2. http://www.ico.gov.uk/
3. https://m.oxfordshire.gov.uk/cms/sites/d...
4. https://www2.oxfordshire.gov.uk/cms/site...
5. http://owls.oxfordshire.gov.uk/wps/wcm/c...
6. https://www.wildoxfordshire.org.uk/biodi...
7. https://news.oxfordshire.gov.uk/county-c...
8. https://m.oxfordshire.gov.uk/cms/sites/d...
9. https://www.oxfordshire.gov.uk/sites/def...
10. https://www.oxfordshirefloodtoolkit.com/...
11. https://www.oxfordshirefloodtoolkit.com/...
12. https://www.adderburypc.co.uk/securedocs...
13. mailto:[email address]
14. https://ico.org.uk/
15. mailto:[email address]
16. http://www.oxfordshire.gov.uk/
17. https://webmail.tiscali.co.uk/cp/ps/Mail...
18. http://www.oxfordshire.gov.uk/emaildiscl...
19. https://www2.oxfordshire.gov.uk/cms/site...

We don't know whether the most recent response to this request contains information or not – if you are tim wells please sign in and let everyone know.