
Introduction
Information exchanges by all partners involved in exchanging information to meet
crime and disorder objectives must be covered by an Information Sharing protocol.
The public are entitled to a high level of protection of their personal data and even
de-personalised information and the protocol must govern what happens to the data
at all stages of the information sharing process. Protocols are designed to promote
trust between partners and the public they serve. Maintaining trust is an essential
in ensuring the continued development of information sharing based activities.
The Information Sharing Protocol must set out and clearly outline the legal basis
for disclosing personal and other types of sensitive information including certain
types of de-personalised information. They inform the data holder and the recipient
of their obligations to safeguard information and duty to comply with relevant legislation,
principally the Data Protection Act and it's eight data protection principles.
There is no ideal size, length, format or form of words to be adopted, when producing
an information sharing protocol. The structure will largely be determined by local
factors and the categories of crime, which the partnership prioritises. The only essential
requirement is that it is ‘fit for the purpose’ for which it is intended.
A number of protocols are already in existence in a variety of formats. Some are
lengthy, legalistic, extraordinarily detailed, whilst others are much more simple.
There is no right or wrong approach in this respect, as long as the protocol clearly
states and incorporates the legal basis of the exchange and the measures to be adopted
prior to and after the exchange of information, to ensure full compliance with relevant
legal requirements at all times.
The information sharing protocol should be a living document. It will need to be
developed and adapted over time, as the role of the partnership and the needs of partners
and the local population change.
Each partner is recommended to nominate a designated officer(s), with responsibility
for regulating, monitoring and acting as a channel, through which requests for information
are made, handled and routinely audited. The partnership should also ensure that there
is a senior officer with overall responsibility for co-ordinating information sharing
activities in accordance with the crime and disorder strategy.
It is recommended that wherever possible:
the protocol should be simple, clear and easy understand (ideally in 'plain
english'). It should be a working document, clearly structured and easily accessible,
so that partners, employees and members of the public can quickly understand it’s
provisions and enable them to implement it's provisions precisely.
sufficiently detailed guidance should be made available to employees, where
there is a need to comply with any special technical or procedural considerations,
before the data is released. For example, the protocol should insist that data is
accurate before disclosure. The employee may therefore need to check or clean the
information, before disclosure is made. Guidance will be necessary, if this involves
a detailed manual or technical process to achieve this.
The protocol should be ideally be placed on the intranet or internet to ensure
that crime & disorder partners, employees and the public can readily view, your policy
on disclosure.
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