I am writing to acknowledge your request for information dated 9th October 2014.

Our team is dealing with your request and we will be in contact with you soon. If you have any queries about this email, please contact me.

Kind regards

Gillian Hollowell
Senior Freedom of Information/Data Protection Officer
Business Intelligence and Performance Improvement
Northamptonshire County Council
Room 223
County Hall
Northampton NN1 1ED
Tel: 01604 367407
Fax: 01604 367004
[email address]
www.northamptonshire.gov.uk

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Dear Mr Newton

There is no rigid test which can be applied or definition available which
I

can provide to you which is used to identify what job/employment role/s
would

be considered "relevant persons" by Northamptonshire County Council (NCC)
in a

disclosure.

Each SAR would be unique to it own set of circumstances and disclosures of
a

third party would be on a case-by-case basis.  We follow the Data
Protection 1998 Subject access code of Practice guidance issued by ICO.

Kind regards

Gillian Hollowell

Senior Freedom of Information/Data Protection Officer

Business Intelligence and Performance Improvement

Northamptonshire County Council

Room 223

County Hall

Northampton NN1 1ED

Tel: 01604 367407
Fax: 01604 367004

[1][email address]

[2]www.northamptonshire.gov.uk

[3]NEW Wordle alternative

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Dear Mr Newton

Our response in relation to your posed question stands. Not withstanding this, whilst we have indicated that we follow the Subject Access Code of Practice guidance issued by ICO, we also advised that each SAR would be unique to it own set of circumstances and disclosures of a third party information would be on a case-by-case basis. NCC does not record or hold a policy detailing guidance which should be followed when dealing with a subject access request. Ultimately, we would refer to source legislation, being the DPA 1998 if we had any queries in relation to the application of the same we would seek guidance from our Legal team.

We should also take this opportunity to advise you that we have looked at the document which your urn refers to dated 2000 and I feel that in my opinion this is a somewhat dated reference document as it makes reference to the responsibilities of the Data protection commissioner (DPC) formerly the Data Protection Registrar now known as the Information Commissioners Office.

SARs will be requested by a variety of individuals from the organisations which may hold information in relation to them; I am sure there are many different guidance documents published by various organisation as to how they feel the process should be conducted. However, as previously stated a request comes with its own unique set of circumstances and therefore one set of guidance may not always be suitable and the content of the information will dictate what elements of investigation and application of any guidance is deemed suitable for that particular case.

As a result this is why ultimately the source legislation being the DPA 1998 will underpin and dictate how a request is handled.

If this does not resolve the issue to your complete satisfaction, you have the right to apply to the information Commissioner for a decision at the following address:

Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Kind regards

Gillian Hollowell
Senior Freedom of Information/Data Protection Officer
Business Intelligence and Performance Improvement
Northamptonshire County Council
Room 223
County Hall
Northampton NN1 1ED
Tel: 01604 367407
Fax: 01604 367004
[email address]
www.northamptonshire.gov.uk

show quoted sections