Sift Manual

W Hunter made this Freedom of Information request to Information Commissioner's Office This request has been closed to new correspondence. Contact us if you think it should be reopened.

The request was partially successful.

Dear Information Commissioner's Office,

Please provide a copy of and any advice /. guidance information for the use of, the ICO Sift Manual.

Yours faithfully,

W Hunter

Information Access Inbox, Information Commissioner's Office

Thank you for contacting the Information Commissioner’s Office. We confirm
that we have received your correspondence.

If you have made a request for information held by the ICO we will contact
you as soon as possible if we need any further information to enable us to
answer your request. If we don't need any further information we will
respond to you within our published, and statutory, service levels. For
more information please visit:

[1]https://ico.org.uk/about-the-ico/our-inf...

If you have raised a new information rights concern - we aim to send you
an initial response and case reference number within 30 days.

If you are concerned about the way an organisation is handling your
personal information, we will not usually look into it unless you have
raised it with the organisation first. For more information please see our
webpage ‘raising a concern with an organisation’ (go to our homepage and
follow the link ‘for the public’). You can also call the number below.

If you have requested advice - we aim to respond within 14 days. 

If your correspondence relates to an existing case - we will add it to
your case and consider it on allocation to a case officer.

Copied correspondence - we do not respond to correspondence that has been
copied to us.

For more information about our services, please see our webpage ‘Service
standards and what to expect' (go to our homepage and follow the links for
‘Report a concern’ and ‘Service standards and what to expect'). You can
also call the number below.

For information about what we do with personal data see our [2]privacy
notice.

If there is anything you would like to discuss with us, please call our
helpline on 0303 123 1113.

Yours sincerely

The Information Commissioner’s Office

Our newsletter

Details of how to sign up for our monthly e-newsletter can be found
[3]here.

Twitter

Find us on Twitter [4]here.

 

References

Visible links
1. https://ico.org.uk/about-the-ico/our-inf...
2. https://ico.org.uk/global/privacy-notice/
3. https://ico.org.uk/about-the-ico/news-an...
4. http://www.twitter.com/ICOnews

Information Commissioner's Office

12 November 2019

 

Case Reference Number IRQ0882552

 

Dear W Hunter

I am currently working to complete your information request related to the
ICO’s Sift Manual. Unfortunately I require more time to prepare our
response to this request, and therefore will not be able to respond within
the statutory time period.
 
I will respond as soon as I am able – I hope that it will be within the
week. Thank you for your patience in this regard.
 
If you wish to contact me, please quote the reference number at the top of
this email.
 
More information about the Information Commissioner’s Office and the
legislation we oversee is available on our website at
[1]https://ico.org.uk.
For information about what we do with personal data see our [2]privacy
[3]notice. Our retention policy can be found [4]here.

Yours sincerely
 
Aiden Clarkson
Senior Information Access Officer
Information Commissioner’s Office

 

 

References

Visible links
1. https://ico.org.uk/
2. https://ico.org.uk/global/privacy-notice/
3. https://ico.org.uk/global/privacy-notice/
4. https://ico.org.uk/media/about-the-ico/p...

Information Commissioner's Office

1 Attachment

26 November 2019

 

Case Reference Number IRQ0882552

 

Dear W Hunter

This is a response to your request for information, which we received on
15 October. I apologise for the delay in responding – the ICO is
experiencing an unprecedented demand on our services, which means that
it’s taking us longer than we would like to respond to some requests.
 
Your request
 
You asked us for:
 
‘A copy of and any advice / guidance information for the use of, the ICO
Sift Manual.’
 
We have processed your request under the Freedom of Information Act (FOIA)
2000.
 
Our response 
 
Please find attached a copy of our Sift Manual. The manual is
self-contained; we don’t hold any other specific advice or guidance
information for its use as none is necessary.
 
As you will notice, some information has been redacted from the manual.
 
We have withheld some information under section 40(2) of the FOIA, because
it is the personal data of other individuals. We consider that disclosure
of that information in response to your request would be unfair, and not
in-line with the principles of data protection.
 
We have also withheld some internal email addresses used for the
processing of internal correspondence once it is received by us through
our public-facing email addresses. We are withholding them under section
36 of the FOIA. 
 
Section 36(2)(c) states:
 
“(2) Information to which this section applies is exempt information if in
the reasonable opinion of a qualified person disclosure of the information
under this Act— 
 
 

 3. would otherwise prejudice, or would be likely otherwise to prejudice,
the effective conduct of public affairs."

We have an established system to manage the flow of correspondence into
the ICO. It is important for efficiency, security, case management and
compliance with retention schedules that this system is maintained and not
circumvented. To disclose internal ICO email addresses which are part of
this system exposes us to the considerable risk that they could be used
inappropriately and indiscriminately, with the potential to cause
disruption to our ability to effectively carry out our function and
deliver services to the public.

We also have concerns regarding the security risks which come with
releasing internal email addresses into the public domain. Multiplying the
potential vectors by which a phishing attempt or other cyber-attack might
occur could lead to such an attack occurring, which would delay the
performance of our duties until the problem was resolved.

The risks described above clearly show that disclosure of this information
would be likely to cause prejudice to the effective conduct of public
affairs.

In order to withhold information under section 36 of the act a public
authority must be supported by the opinion of its “qualified person.” The
ICO’s qualified person is the Commissioner, Elizabeth Denham CBE.
 
I have not directly sought the opinion of our qualified person in this
instance, because I am satisfied that we can rely upon an opinion she
provided on a very similar request earlier in the year. That request was
not limited to the sift manual but requested a list of all email addresses
ending in @ico.org.uk. The rationale for withholding all internal email
addresses is the same as the rational for withholding the specific
internal email addresses contained within the document you have requested
from us.
 
Therefore I am relying upon the Commissioner’s earlier opinion that
section 36 of the FOIA was engaged in relation to that request, and I am
satisfied that it can be extended to the information I am withholding in
response to your request.

Section 36 is a qualified exemption, so I must consider the balance of the
public interest in disclosure.
 
The factors in favour of disclosing the information are: 

 

* There is some public interest in disclosing information about the way
the ICO handles incoming correspondence; in my opinion this public
interest is broadly met through the provision of the Sift Manual,
albeit with minor redactions.

 
The factors in favour of maintaining the exemption are: 
  
 

* The ICO already provides a number of contact email addresses on its
website. It also has a helpline for telephone requests, a live chat
facility for keyboard communication and a postal address for written
correspondence. We can see no further benefit to the public in
disclosing specific internal email addresses when the public should
have no need to use them, and any correspondence which could be
directed to them will be served equally well if sent to our publically
available contact addresses.
* There is a real concern that the disclosure of the information would
hinder our ability to perform our core functions. It is in the public
interest that the organisation is able to perform its role as
regulator.
* Releasing the information would result in an increase to our IT
vulnerability. There is no public interest in risking the level of
service we provide to the public.

Next steps
 
I hope this response is clear. If you would like me to clarify anything
about the way your request has been handled please contact me.
 
You can ask us to review the way we have handled your request. Please see
our review procedure [1]here.
 
If you remain dissatisfied with the way we have handled your request
following an internal review you can [2]report your concern to the
regulator.
 
If you wish to contact me, please quote the reference number at the top of
this email. If you reply to this email please leave the subject field
unchanged.
 
More information about the Information Commissioner’s Office and the
legislation we oversee is available on our website at [3]www.ico.org.uk.
For information about what we do with personal data see our [4]privacy
notice. Our retention policy can be found [5]here.
 
Yours sincerely
 
Aiden Clarkson
Senior Information Access Officer
Information Commissioner’s Office
0330 414 6827

 

References

Visible links
1. https://ico.org.uk/media/1883/ico-review...
2. https://ico.org.uk/make-a-complaint/
3. http://www.ico.org.uk/
4. https://ico.org.uk/global/privacy-notice/
5. https://ico.org.uk/media/about-the-ico/p...