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Job Description
Job Title
Data Protection and
Freedom of
Information Officer
Reporting
to
Ethics, Integrity and Public
Interest Manager TBC
Job Ref
Purpose
To take ownership of, and provide expert guidance for the CEO’s statutory
obligations in respect of Information Law; to inform and set the strategic direction
for information management; develop and maintain Information Management
policies, toolkits, guidance and awareness programmes to meet statutory
requirements and contribute to / comply with relevant national police policy.
To manage and influence reputational risk and maximise the value and integrity of
the College of Policing’s information, supporting a drive for transparency and the
sharing of information where it contributes to improved policing outcomes.
To provide the CEO with an Information Management capability delivering and
acting as the final arbiter on the interpretation and application of the following
legislation:

Article 8 (right to ‘privacy’) European Convention on Human Rights

The Data Protection Act 1998

Freedom of Information Act 2000 (FoIA)

The Environmental Information Regulations 2004

Management of Police Information (MoPI) Codes of Practice 2010

Protection of Freedoms Act 2012 (in relation to information law requirements)
Accountabilities
1.
Maintaining an up-to-date expert knowledge of, and advising, relevant
legislation, case law and general developments in information law matters.
This includes College-wide responsibility for delivering information law
compliance strategy, policies, procedures and guidance in line with the
above legislation and other relevant legislation;
2.
Monitoring and supervise corporate compliance with the various information
© College of Policing 2013
law / policy requirements; problem-solving and taking action where
concerns are identified either through the provision of training and tailored
support etc. or escalation to the SIRO;
3.
Securing individuals rights under the above Acts, including subject access
requests, FoIA requests legislative complaints investigations and individuals
rights to stop further processing;
4.
Assist Human Resources, Investigation and Complaint managers and
Membership in the investigation of disciplinary and criminal matters relating
to legislative breaches and criminal offences
5.
Developing and formally approving Privacy Impact Assessments, information
sharing agreements, Data Processing Agreements and MoUs.
6.
Taking proactive responsibility for managing all matters relating to
information law compliance, including acting as the designated Regulator
and key stakeholder contact. This includes formally responding on behalf of
the College to all formal enquiries regarding the above legislative
requirements and representing the College of Policing on national forums
and active participation in the development of the research and creation of
national policy and guidance on information law matters.
7.
Liaising with the College and Home Office legal teams with regard to
advising on disclosure cases, Information Tribunal cases and application of
legislation around ad hoc complex issues.
Dimensions
People
Management
Budget £

Privacy and Transparency Case Worker

No direct budgetary responsibility
Other

Impact
Key indicators
of success



© College of Policing 2013
Managing and protecting the College of Policing’s reputational
and brand profile through the development of an effective
information law risk management programme
Influencing organisational engagement in the College
statutory compliance requirements at every level
Leading on the creation and implementation of an effective



Essential Criteria
College information law compliance programme that sees the
development of corporate information compliance contract
templates, audits, policies, toolkits and national MoUs /
Agreements.
Fostering and managing key national and international
stakeholder relationships to further the College’s information
law compliance standards through the gathering of best
practice techniques and being the College / CEO
representative at all national and international information
law forums. This will include establishing excellent working
relationships with regulators and ombudsman on all
information law compliance matters.
To lead on the College statutory information request handling
programme ensuring that 95% of requests are responded to
within the statutory deadlines, with <20% of cases leading to
Internal Review stages, <10% leading to ICO involvement
and <1% leading to Information Tribunal.
To ensure that the organisation has access to leading and
compliant information law advice, guidance and steer within 5
working days of commission and 24 hours where it is an
Executive level request (dependent upon the complexity of
the advice sought).
– Training and Qualifications

Educated to degree level or relevant equivalent experience

Hold an ISEB qualification in Data Protection 1998,
Or

IAPP CIPP/E
And

Hold an ISEB qualification in Freedom of Information 2000 and Environmental
Information Regulations 2004

Alternatively, have significant proven relevant experience in the application of
the above in real world situations. In the absence of the above qualifications
the successful candidate MUST commit and achieve at least one certificate
within 8 months of appointment.
© College of Policing 2013
Desirable:

Membership to relevant professional bodies (e.g. International Association of
Privacy Professionals).

LLM Information Rights Law and Practice (or equivalent).
Vetting Level: SC
Essential Criteria – Experience

Experience of interpreting and applying legislation and setting policy and
guidance.

Proven experience of Risk Management and applying a risk management
strategy in line with the corporate risk appetite.

Experience of building excellent working relationships with internal and external
stakeholders including Ombudsmen and Regulators.
Experience of solving complex technical issues and problems in relation to
transparency and privacy requirements
Essential Criteria – Skills and Knowledge
 Proven senior Leadership and Motivational Skills.

Ability to process and digest large amounts of information within short
timescales on new subject areas which maybe technically complex with a high
attention to detail

Excellent oral and presentation skills are essential to make valid and powerful
arguments with senior officers / staff, members of the public and
representatives of partner agencies, legal firms and the media. Such skills
include the ability to explain complex legal and security issues to non-experts
at all levels within the organisation, identifying options to tackle issues of risk
and taking appropriate action.

Excellent written skills in order to make succinct and compelling cases to
robustly defend the College of Policing position with regards to our application
and interpretation of key information legislation etc.

Ability to negotiate compromises between senior information ‘owners’ who may
© College of Policing 2013
be resistant to disclosure by offering convincing alternatives and preferred
options.

Personal resilience to counter argue with decision-making to achieve the best
outcomes for policing and defend the Colleges position.

Desirable Criteria
 Background / understanding of policing
Other Information
 Vetting level: SC
 Will require occasional travel to all College of Policing sites and to those of
Policing-related organisations in England and Wales
 Must apply and promote the College of Policing Code of Ethics
Org Chart
See overall structure chart
Authorisation
Prepared by
Authorised
© College of Policing 2013
Version V
Date
Date