7 Tweedside Park
Tweedbank
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
GALASHIELS
TD1 3TE
www.sppa.gov.uk
Tel: 01896 893238
Fax: 01896 893214
xxxxxx.xxxxxxx@xxxxxxxx.xxx.xxx.xx
Our ref: FOI/14/01949
17th December 2014
Dear Mr Caulfield,
REQUEST UNDER THE FREEDOM OF INFORMATION (SCOTLAND) ACT 2002 (FOISA)
Thank you for your request for information under the Freedom of Information (Scotland) Act 2002
dated 29th November 2014, concerning consent to share sensitive personal data.
Your request
SPPA have taken over the administration and payment of Police pensions in Scotland. Personal
data has been transferred from Police Scotland to SPPA via two private companies: Heywood
Limited, suppliers of pension software used by SPPA, and EDM Group, contracted the task of
scanning documents.
1. Please specify any action taken or considered to obtain consent of Police Pensioners to
process their personal data prior to transfer?
2. Please specify any action taken or considered to obtain explicit consent in respect of
pensioners sensitive personal data?
3. Please specify any action taken or considered to obtain pensioners consent to disclose
their processed data to third party private companies ie. Heywood Ltd and EDM Group?
4. Please supply copies of any correspondence, documents, e mails between SPPA and
Police Scotland relevant to obtaining consent of data subjects prior to transfer of Police
pensions to SPPA?
Response to your request
Questions 1-4: We do not hold the information you have requested.
All Police
Pensioners were
informed of the new Data Controller arrangements and the transfer of data by means of a ‘Fair
Processing Notice’ issued by the current administering authorities and the Scottish Police
An agency of
Authority on behalf of Police Scotland. In addition, SPPA has agreed data transfer protocols with
each of the existing administering authorities.
Your right to request a review
If you are unhappy with this response to your FOI request, you may ask us to carry out an
internal review of the response, by writing to Neville Mackay, Chief Executive (at the address
above). Your review request should explain why you are dissatisfied with this response, and
should be made within 40 working days from the date when you received this letter. We will
complete the review and tell you the result, within 20 working days from the date when we
receive your review request.
If you are not satisfied with the result of the review, you then have the right to appeal to the
Scottish Information Commissioner. More detailed information on your rights is available on the
Commissioner’s website at:
www.itspublicknowledge.info. Yours sincerely
Marion Chapman
Director of Corporate Services
An agency of