Publication - FOI/EIR release

FOI redactions process under General Data Protection Regulation (GDPR): FOI release

Published: 15 Apr 2019

Information request and response under the Freedom of Information (Scotland) Act 2002.

Published:
15 Apr 2019
FOI redactions process under General Data Protection Regulation (GDPR): FOI release
FOI reference: FOI/19/00783
Date received: 18 Mar 2019
Date responded: 11 Apr 2019
Information requested

Further to this article about the quality of your FOI responses and redaction - https://theferret.scot/sturgeon-nuclear-waste-protestor/ can you please provide the following information:

  1. What software/program was used to redact the documents?
  2. Have staff been trained with regards to redaction of FOI and information rights under the GDPR
  3. If so, please provide any slides or documentation that were used in this training.”
Response

I enclose a copy of most of the information you requested.  Please see details below:

  1. What software/programme was used to redact the documents?

Adobe Acrobat Pro.

  1. Have staff been trained with regards to redaction of FOI?

Most of the information you have requested is available from the Scottish Government Freedom of Information (FOI) sharepoint site.  The sharepoint site is available for anyone to view externally: https://foiguidance.sgworksite.org.uk/ (username: SCOTLAND\foi and password: Scotland1).

The sharepoint site has a specific page on FOI training material that includes our e-learning module, which all Scottish Government staff are expected to undertake.  The e‑learning module contains a section on redaction: https://foiguidance.sgworksite.org.uk/Guidance/Training.aspx. It also includes a section on redacting information: https://foiguidance.sgworksite.org.uk/Guidance/Redacting%20information.aspx

Under Section 25(1) of FOISA, we are not required to give you information which is already reasonably accessible to you.  If, however, you do not have internet access to obtain the above information from the sharepoint site, then please contact me again and I will send you a paper copy.  This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

The sharepoint guidance on redacting information refers to ‘General Guidelines for redaction and the Specific Guidelines for Formats’.  The information guidelines are available on our intranet and they include guidance on redacting information using Adobe Acrobat.  These documents are included in the attached schedule.

  • Have staff been trained with regards to information rights under the GDPR?

The Scottish Government Data Protection and Information Asset Team delivered forty‑six face to face training sessions (approx. 625 staff based in Edinburgh, Glasgow, Falkirk, Aberdeen, Galashiels) as part of the GDPR implementation project.  Those sessions focused on key changes brought by the new legislation, including handling information rights requests.  I have included the slides and awareness raising material which specifically refers to information rights requests under GDPR.  These documents are included in the attached schedule.

The Scottish Government Data Protection and Information Asset Team developed a data protection eLearning module to include information on the new GDPR.  I have included an extract from the eLearning which specifically refers to information rights requests under GDPR (see document schedule attached).

The table below provides current statistical information with regards to the Scottish Government data protection e-learning module pass rate – as at 3 April 2019.

Date Pass Fail No Test Renewal Total
03/04/2019 10072 13 357 0 10442

There is guidance for staff on information rights requests under the General Data Protection Regulation (GDPR).  There is  also guidance for staff on redaction of subject access request.  These documents are included in the attached schedule.  In addition, there is guidance available on the FOI sharepoint site (log in details as above) on general approach on individuals names – 

https://foiguidance.sgworksite.org.uk/Guidance/Individuals%e2%80%99%20names%20(including%20officials).aspx

  • If so, please provide any slides or documentation that were used in this training.

Please see document schedule attached.

About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at http://www.gov.scot/foi-responses.

Contact

Please quote the FOI reference
Central Enquiry Unit
Email: ceu@gov.scot
Phone: 0300 244 4000

The Scottish Government
St Andrews House
Regent Road
Edinburgh
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