Mike Greene, Chief Executive, SBC
To be fully compliant with the DPA and GDPR when handling Data, not only must SBC be a registered Data Controller, but so must ALL 46 SBC Councillors individually. Failure to be registered is a breach in itself.
Service Level Agreement
As ALL 46 SBC Councillors are separate and individual Data Controllers, as is the Council, they must take full responsibility to ensure ALL Data sent to them or stored by them is handled in a manner that complies with Data legislation and principles.
If there is no Service Level Agreement in place between an SBC Councillor and SBC, the body corporate, SBC MUST NOT have access to any emails sent to the Councillor in question. Currently, SBC “intercept” all emails sent to Councillors at their SBC email addresses.
I am of the opinion that all emails sent by residents to SBC Councillors via their SBC email addresses are handled in breach of legislation by SBC.
Not only are SBC guilty of the breach, but every Councillor is also in breach of legislation by permitting SBC to handle Data that is addressed to them, and them alone, and to which they have a legal duty to process lawfully.
It is fundamental to note that a Code of Practice is nothing more than an aspiration. Conversely, a Service Level Agreement is a contractually binding obligation.
Subject Access Request
Everyone has the right to ask a Data Controller, free of charge, whether or not they are using or storing their personal information. You can also ask them for copies of your personal information, verbally or in writing.
This is called the right of access and is commonly known as making a Subject Access Request or SAR.
Email To Mike Greene, Chief Executive, SBC
In the interests of transparency, could I please refer you to (LINK)
Could I please make a Freedom of Information request for copies of all current (appropriately redacted) Service Level Agreements between SBC and each of the 46 SBC Councillors?
As someone on the naughty table could you please advise me:
- How I can make a Subject Access Request to SBC?
- How I can make a Subject Access Request to any or all of the 46 SBC Councillors in a manner that does not breach Data legislation or principles?
Enjoy your weekend.