Data Protection Impact Assessments (DPIAs)

Response

 

I’m seeking copies of the following Data Protection Impact Assessments prepared by Avon & Somerset Police, identified in your response to my previous FOI request (reference 1321-23):

 

• Crime & Intelligence App
• Location Management App

We have not identified any Data Protection Impact Assessment (DPIA) held for either the Crime & Intelligence App or Location Management App. Though listed within our previous response, upon further research we have established that these were earlier references to the DPIAs held under the names ‘Crime & Intelligence Qlik App’ and ‘Location Management Qlik App’. As stated below, copies of those DPIAs have been provided.

 

• Offender Management App

 

Please find attached a copy of the signed DPIA for this App.

 

• Location Management Qlik App

 

Please find attached a copy of the signed DPIA for this App.

 

• Crime and Intelligence Qlik App

 

Please find attached a copy of the signed DPIA for this App.

 

• Sex Worker & Prostitution Qlik App

 

We have been unable to locate a signed copy of this DPIA within our files. An unsigned, draft version has been identified and, in the interests of transparency, has been attached here. You will note that this includes comments, recommendations and sections highlighted for further review. This serves to emphasise that the information provided is not a completed DPIA and may not be reflective of any eventually agreed processing.

 

Please also note that the relevant Qlik app that is now in place is referred to simply as the Sex Work App.

 

• Potential Offenders Dashboard

 

While a draft DPIA was produced by Avon and Somerset Police, it was not signed off by the Data Protection Officer due to concerns with the proposed processing. The proposed processing has not been approved or put in place by Avon and Somerset Police and no Potential Offenders Dashboard exists on our systems.

 

Nonetheless, a draft version of the DPIA having been prepared by Avon and Somerset Police, this has been attached here in the interests of transparency. Once again, this includes comments, recommendations and sections highlighted for review, reflecting the fact that this was not an approved or completed DPIA.

 

Within the signed DPIAs provided, names other than those of the senior officer responsible for its approval have been redacted in line with the following exemption:

• Section 40(2) Freedom of Information Act 2000 – Personal Information.

Any information to which a request relates is exempt if it constitutes personal data and would contravene any of the data protection principles.

Personal data relates to a living individual who can be identified directly from the information, or identifiable indirectly in combination with other available information.

This is an absolute exemption if disclosure would breach any of the data protection principles. This means that we cannot be compelled to disclose information in the public interest.

A Freedom of Information disclosure is a disclosure to the world. Therefore, information that is provided can be viewed by any member of the public. Should information be provided from which a living individual could be identified this would constitute a breach of rights provided under the Data Protection Act 2018. Information held on an individual by Avon and Somerset Police is done so lawfully and is used for a policing purpose in line with the principles set out in the UK GDPR. Our privacy policy can be viewed here.

This serves as a partial refusal notice under section 17(1) of the FOI Act.