Dear Imperial College London,
1) 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 which was written in the last 5 years
5) a list of any policies implemented in the last 2 years within the organisation to help reduce the environmental impact that the organisation has?
Dear Mr Wells,
This is to acknowledge receipt of your request below, made under the Freedom of Information Act. The College will respond to your request by 20th January 2020.
Freedom of Information Team
Imperial College London
Dear Mr Wells,
Thank you for your recent Freedom of Information request. Please find
below the College's response to your questions.
1) Please can you send me a copy of the current subject access request
acknowledgment AND response letter that you use
Please see the attached document ‘SAR acknowledgement and response
2) A copy of the last 5 dpias completed
Please find attached the last five Data Protection Impact Assessments
completed by College.
Redactions have been applied to the documents to remove personal
information such as names. This information is exempt from disclosure
under Section 40 (2) of the Freedom of Information Act, which states that,
"any information to which a request for information relates is also exempt
information if - (a) it constitutes personal data."
Information about the physical location of stored trial data is also
exempt from disclosure under Section 31 (1) of the Freedom of Information
Act, which states that information is exempt if “its disclosure would, or
would be likely to prejudice the prevention or detection of crime…[or be
likely to prejudice] the apprehension or prosecution of offenders.”
This information, if released, may make the College more vulnerable to
crime as the location of clinical trial data, which includes personal
data, would be known, potentially making the College a target of crime.
In the College’s view there is not sufficient public interest in releasing
this information to outweigh the potential impact of the release of the
data. Further, it is itself in the public interest that the College does
its best to maintain the security and safety of students, staff, and the
general public when on College property.
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
We are unable to provide a copy of the requested training because the
training packages are the intellectual property of third party providers.
This information is therefore exempt from disclosure as it is commercially
sensitive. Its disclosure would prejudice the commercial interests of the
training providers by making its product publically available. This could
lead to a loss of business and income. As such this information is exempt
from disclosure under Section 43 (2) of the Freedom of Information Act.
Section 43 (2) states that information is exempt if its disclosure “would
or would be likely to, prejudice the commercial interests of any person
(including the public authority holding it).” We do not believe the public
interest in the release of this information outweighs the potential impact
of the disclosure of this information.
4) A copy of any instructions given to staff members to reduce data
security breaches, for example double checking work which was written in
the last 5 years
Published guidance is available on the College’s Data Protection
webpages. To locate, extract and collate any written guidance that has
been given on an ad hoc basis to staff would take in excess of 18 hours
and is therefore exempt from disclosure under section 12 (1) of the
Freedom of Information Act. This is because it would be necessary to write
to all members of staff and ask them to check their correspondence for any
guidance they have been sent relating to data security breaches.
Section 12 of the Freedom of Information Act states that “Section 12 (1)
does not oblige a public authority to comply with a request for
information if the authority estimates that the cost of complying with the
request would exceed the appropriate limit (under the Freedom of
Information and Data Protection (Appropriate Limit and Fees) Regulations
2004).” The appropriate limit is set at 18 hours.
5) A list of any policies implemented in the last 2 years within the
organisation to help reduce the environmental impact that the organisation
Drinking water is freely available in all of our catering outlets, either
from drinking fountains or provided in jugs and carafes.
Meat-free options are available at all of catering outlets. Vegan outlets
are also available. Full details all of Imperial College’s catering
outlets and selected menus is available on our website here:
Some of our recent sustainability initiatives are:
· We charge a levy on hot and cold drink orders served in
disposable/single-use cups. We recommend customers use a renewable coffee
cup, with a variety of options available to purchase at cafes and shops
· We have removed single-use plastic glasses from catering outlet
water stations – saving up to 850,000 cups/year (from Oct 2018).
· Introduction of ‘bring your own container’ for hot, portioned
takeaways from all Campus Services catering outlets (from Nov 2018).
· Replacement of single-use plastic cutlery with FSC-certified
reusable wooden cutlery from Dec 2018.
· A trial of Meat Free Monday in January 2019.
Please see the Greening Imperial pages for further details of Imperial
College’s achievements and initiatives to improve sustainability.
If you are unhappy with the way that we have handled your request, you can
ask us to conduct a review. Please make your representation in writing
within 40 days of the date you received this response. If you remain
dissatisfied with how Imperial College has handled your request you may
then approach the Information Commissioner’s Office.
Freedom of Information Team
Imperial College London
We work to defend the right to FOI for everyone
Help us protect your right to hold public authorities to account. Donate and support our work.Donate Now