Data Protection Compliance

Response to this request is long overdue. By law, under all circumstances, Northamptonshire Police and Crime Panel should have responded by now (details). You can complain by requesting an internal review.

Dear Sir/Madam,

I am writing to make a formal request for information under the provisions of the Freedom of Information Act 2000. I kindly request that you provide me with the following information:

1. A copy of your organisation's Records of Processing Activity (ROPA) as defined in Article 30 of the UK General Data Protection Regulation (UK GDPR).

2. A copy of all legitimate interest assessments conducted by your organisation where you rely on Article 6(1)(f) legitimate interests as your lawful basis for processing.

3. A copy of all privacy impact assessments conducted by your organisation.

4. A copy of all data protection impact assessments conducted by your organisation.

5. A copy of all international transfer risk assessments conducted by your organisation.

6. A recent copy of your organisation's data protection compliance assessment using the Information Commissioner's Office (ICO)'s accountability framework template. If you are using your own standards to monitor compliance with the Data Protection 2018, please provide me with copy of it.

7. A copy of your organization's data protection policy.

8. A copy of your organization's subject access request policy, procedures, and processes, including any guidance material such as folder structure, naming conventions, and redaction guides.

9. A copy of your organisation's privacy notices, including but not limited to employees, customers, ministers, special advisors (SPADs), complaints, NEDS, visitors, and CCTV.

10. A copy of your organisation's due diligence questions for vendor management such as independent data controllers or processors.

I understand that under the Freedom of Information Act, you are required to respond within 20 working days. To stay within section 12 - cost limits, I suggest asking your Data Protection Officer for the information. If this is not possible, I suggest a search of your compliance platform and your Microsoft estate for the following search terms (not case sensetive):

1. "records of processing activity" OR "ropa"
2. "legitimate interest assessment" OR "LIA"
3. "privacy impact assessment" OR "privacy impact assessments" OR "PIA"
4. "data protection impact assessment" OR "DPIA"
5. "transfer risk assessment" AND "personal data"
6. "accountability framework"

I would prefer to receive the requested information in electronic format via email.

Should you require any clarification or further details in order to process this request, please do not hesitate to contact me. I would be grateful if you could confirm receipt of this request and provide a reference number for future correspondence.

Thank you for your attention to this matter. I look forward to receiving the requested information within the statutory timeframe.

Yours faithfully,
Jay Bhanji

James Edmunds, Northamptonshire Police and Crime Panel

Dear Jay Bhanji,

The Northamptonshire Police, Fire and Crime Panel is a joint committee of North Northamptonshire Council and West Northamptonshire Council that is responsible for scrutinising the work of the Northamptonshire Police, Fire and Crime Commissioner. The Panel is not an organisation in its own right.

The Panel is administered by Democratic Services at West Northamptonshire Council. Information about how to make a Freedom of Information request to the Council is available at:


James Edmunds

Assistant Manager
Democratic Services

West Northamptonshire Council | One Angel Square | Angel Street | Northampton | NN1 1ED
Tel: 07500 605276 |
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I am working flexibly. If you receive this email outside of your own working hours please be reassured that I do not expect an immediate response. I look forward to hearing from you during your working hours.

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Dear James Edmunds,

Please withdraw this FOIa request.

Yours sincerely,

Jay Bhanji