Data Protection Officer

Roedd y cais yn llwyddiannus.

Dear Aberdeenshire Council,

1. Could you let me know?

a. What position in the Council is designated as Senior Information Risk Owner (SIRO)?
b. The name of your Data Protection Officer (DPO)?
c. Job title of the DPO, if not just DPO?
d. If the DPO also has other duties, approximately how much of their time is spent on DPO work?
e. If the DPO has other responsibilities, has a risk assessment been carried out to ensure that any potential conflicts of interest as identified in the GDPR and the guidance from the European Data Protection Board are managed? If so, has this been reviewed in light of the recent decision of the Belgium Data Protection Authority (28 April 2020):
f. The line manager of the DPO – i.e. the post that the post holder reports to. Is it the SIRO?
g. Who the DPO reports to in their role as DPO if that differs from the line manager? Is it the SIRO?
h. At what spinal point is the DPO paid?
i. Key relevant qualifications that the DPO and SIRO hold or relevant training completed.

2. And could you provide the relevant extract of the Council’s Organisational Chart that shows the DPO, the DPO’s line manager, the post holder that the DPO reports to, the SIRO and Chief Executive?

Yours faithfully,

Caroline Smith

Acknowledge email,

Dear Sir/Madam,

Thank you for your information request.

Due to the Coronavirus (COVID-19) outbreak, we might not be able to answer
your information request within its statutory timescale.

The Council has legislative duties to respond to this emergency and we are
working hard to make sure that resources are focused on delivering and
supporting essential services. As responding to information requests could
divert key staff from delivering and supporting essential services, we
would appreciate at this time if you could please consider whether your
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To withdraw your request please reply to this email advising as such and
ensuring the you keep the subject line the same. If your request is
critical to the handling of the pandemic please also let us know via
[Aberdeenshire Council request email]

Thanks in advance for your co-operation

Information Requests Privacy Notice: [1]

Aberdeenshire Information Enquiries


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FOI Legal, Aberdeenshire Council

1 Atodiad

Dear Ms Caroline Smith

Data Protection Officer - Freedom of Information (Scotland) Act 2002 (“The

I refer to your recent request in respect of the above and attach herewith
our response for consideration.

Please contact me as the officer responsible for responding to your
request if you have any further queries.

If, for any reason, you are not satisfied with this response, please refer
to the further information attached.

Yours faithfully

Freedom of Information Co-ordinator
Business Services: Legal & Governance

Further Information:
Aberdeenshire Council’s Review Procedure under the Freedom of Information
(Scotland) Act 2002 and the Environmental Information (Scotland)
Regulations 2004 can be accessed at the following link:


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