Annual Equality Information Publication...ICO Equality Duty Annual Information Report, December 2016, v1 Page 2 of 37 Part 1: Introduction to the ICO and this report About the ICO

ICO Equality Duty Annual Information Report, December 2016, v1 Page 1 of 37

Annual Equality Information Publication

December 2016


Part 1: Introduction to the ICO and this report About the ICO The Information Commissioner’s Office (ICO) is the UK’s independent public body set up to promote access to official information and protect personal information. This is achieved by promoting good practice, ruling on complaints, providing information to individuals and organisations and taking appropriate action when the law is broken. The ICO is responsible for the enforcement of the Data Protection Act, Freedom of Information Act, the Privacy and Electronic Communications Regulations and the Environmental Information Regulations. The Freedom of Information Act 2000 gives people a general right of access to information held by public authorities. Aimed at promoting a culture of openness and accountability across the public sector, it enables a better understanding of how public authorities carry out their duties, why they make the decisions they do and how they spend public money. The Environmental Information Regulations 2004 provide an additional means of access for people who want environmental information. The regulations cover more organisations than the Freedom of Information Act, including some private sector bodies. The Data Protection Act 1998 gives citizens important rights, including the right to know what information is held about them and the right to correct information that is wrong. It helps to protect the interests of individuals by obliging organisations to manage the information they hold securely, and gives the ICO the power to take enforcement action against organisations which mismanage or abuse personal data. The Privacy and Electronic Communications Regulations 2003 support the Data Protection Act by regulating the use of


electronic communications used for the purpose of marketing to individuals and organisations. The ICO also has responsibilities for other regulations including aspects of the INSPIRE regulations, the Re-Use of Public Sector Information Regulations, and the Electronic Identification and Trust Services for Electronic Transactions Regulations. The ICO is a UK wide organisation that is committed to appropriately meeting the diverse needs of its many stakeholders and users as well as ensuring a positive and fair working environment for its employees in England, Wales, Scotland and Northern Ireland. About this report The ICO is a public authority and is subject to the Public Sector Equality Duty. This means that the ICO is required to publish information to demonstrate what we have done to help eliminate unlawful discrimination, advance equality of opportunity and foster good relations. We are also obliged to publish equality data concerning our staffing. These obligations are called ‘specific duties’ of the Equality Act. This report is written to fulfil those duties and to help people and organisations assess the ICO’s performance with a focus on equality matters. We want to continually improve our equality performance. We hope that the report demonstrates that equality is integral to our activities, decision making and the effective promotion of information rights. Our Equality Objectives In 2013 we developed and published two overarching equality objectives. These objectives have remained in place during the last year and influenced our corporate plans and how they were delivered.


Essentially, we have one objective which is ‘external’ facing and one which has an ‘internal’ focus. Our external facing objective is:

to extend the ICO’s external reach so that a wider range of individual and organisational users are aware of, and able to access, our services.

In practice this means reaching out to a range of different people with an approach that is relevant and accessible. Our internal objective is:

to mainstream equality understanding and skills within our workforce in order to improve employee experience and our capacity to meet diverse user needs.

This means building the skills of our people so that they can most effectively meet different business needs. A fuller breakdown of the relationship between these overarching equality objectives, our organisational plan for 2016-19 and our actions / measurements for delivery can be found at appendix 1. We intend to review our Equality Objectives in the coming months to tie in with our corporate planning process and ensure that they remain in keeping with our organisational goals. We want our new objectives to focus our ambitions to promote equality of access to information rights, influence the promotion of equality and diversity in other organisations and act as a responsible employer of people. Equality and Diversity Committee To help us monitor our progress towards fulfilling our Equality Objectives, we have an Equality and Diversity Committee. The Committee’s role is to support and advise the organisation in our efforts to achieve our objectives and help us to implement good equalities practice.


The Committee is made up staff from various departments and grades across the organisation, including staff who work in our regional offices. The Committee provides support and expertise, but it is important that it is not regarded as the main ‘owner’ for equality initiatives. We wish to embed equality and diversity in the operational work of the ICO with local accountability resting with relevant departmental and project / activity leads, with involvement from staff across the organisation. We collect information from each of our departments that describe the activities they have undertaken which have an equality and diversity dimension. We report this back to the business to assist planning of future activity. So, by considering equality considerations at the planning stage, we feel we can maximise the impact and benefits of our work. Report structure The next part of this report provides information about the ICO’s staffing including the demographics of our staff and pay equality data. We also provide information about the training provided to our staff which helps them to provide better services to the public. The final part of this report provides more detailed information about actions which have impacted upon our performance on equalities, diversity and good relations. In the appendices of the report we provide examples of the linkages between our Corporate Plan and equality actions, as well as specific examples of actions and outputs of our work and the impact they have on improving equality in our society.


Part 2 Equality Information and the duty This part of this report provides statistical information about the characteristics of our staff. As well as information held within Human Resources records, we have used demographic information from our anonymised staff survey to provide information for this publication. Some data therefore reflects information as at 30 September 2016, whilst other information was gathered during the staff survey in February/March 2016. 2.1 Total Headcount and FTE (established staff) The ICO had 454 staff, which represents a full time equivalent staffing of 420.5 posts. The organisation’s staffing has grown by 15% since the 2015 report was published and by nearly 35% since 2010.

0

50

100

150

200

250

300

350

400

450

500

31.3.10 31.3.11 31.3.12 31.3.13 31.3.14 31.3.15 31.3.16 30.9.16

337 353

350

388 386 392

442 454

313.8 328.5 324.6

359.6 354 363.5

408.6 420.5

Headcount FTE


2.2 Gender analysis

The ICO had 31 new starters from 1 April to 30 September 2016. Of these staff, 42% were male and 58% were female. 2.3 Staffing by grade

Job Level

No. of staff

% of staff

FTE

A 9 2% 8.1

B 36 7.9% 29.8

C 99 21.8% 89

D 136 30% 127.7

E 101 22.2% 95.3

F 58 12.8% 55.55

G 13 2.9% 13

H* 2 0.4% 2

* Level H is the ICO’s most senior grade. Data does not include the Commissioner.

274, 60%

180, 40%

Gender analysis

Female Male


2.4 Grade breakdown by gender

* Level H is the ICO’s most senior grade. Data does not include the Commissioner.

Job Level % of grade female

% of grade male

A 33% 67%

B 72% 28%

C 61% 39%

D 64% 36%

E 60% 40%

F 55% 45%

G 38% 62%

H* - 100%


2.5 Staff by age group

Age Category

% of staff % of new starters since 1.4.16

16-19 - -

20-29 13.7% 20.8%

30-39 31.7% 45.8%

40-49 23.6% 29.2%

50-59 24.7% -

60+ 5.9% 4.2% 2.7 Staff by ethnic origin The information in the table is based on information held on the HR database.

Number of staff % of staff

% of Cheshire

East population

% of Greater

Manchester population

% of United Kingdom

population

Asian and Asian British

9 2%

1.3% 6.52% 4.0%

Black and Black British

6 1.3%

0.6% 1.71% 2.0%

Chinese <5 <1.1% 0.4% 0.78% 0.4% Mixed ethnicity 6 1.3% 0.9% 1.56% 1.2%

Other ethnicity <5 <1.1% 0.3% 0.53% 0.4%

White 387 85.24% 96.7% 88.9% 92% No data provided 39 8.7%


The table below provides information gathered as part of our staff survey. The categories are as used in national census surveys.

Ethnicity Number of respondents

% of respondents

White English/Welsh/ Scottish / Northern Irish / British

306 81%

White Irish <5 2% White Gypsy or Irish Traveller <5 <1.3%

Any other White background <5 2%

Mixed White and Black Caribbean <5 <1.3%

Mixed White and Asian 0 0 Any other mixed or multiple ethnic background

<5 <1.3%

Asian or Asian British Indian <5 <1.3%

Asian or Asian British Pakistani <5 <1.3%

Asian or Asian British Bangladeshi 0 0

Asian or Asian British Chinese 0 0

Any other Asian background 0 0

Black or Black British African <5 <1.3%

Black or Black British Caribbean 0 0

Any other Black / African / Caribbean background <5 <1.3%

Arab 0 0 Any other background 0 0 Prefer not to say 38 10%


2.8 Staffing and disability

% of staff

based on Staff Survey

data

% of staff based on HR

database entries*

Disabled 12% 3.85%

Not disabled 75% 96.15%

Prefer not to say 14%

*The HR database only records a positive declaration if a member of staff considers themselves to be disabled. Other demographic information As part of the 2016 Staff Survey update, respondents were asked to provide demographic information which does not form part of the data held on the individual’s HR record. It was explained that the information would be used to produce data about the characteristics of our staff and help us to fulfil our obligations under the Equality Act and develop future plans. The questions asked related to characteristics which are protected under the Equality Act. The information therefore provides a snapshot of those characteristics. The response rate for the survey was 84% of staff and the figures provided are based only on the responses received ie no information is provided concerning 16% of the ICO’s staff, and staff who did respond were able to state ‘prefer not to say’ in answer to the demographic questions.


2.9 Caring responsibilities Do you look after or give help or support to any family members, friends, neighbours or others who have a long-term physical or mental illness or disability, or problems related to old age?

Yes 16%

No 72%


Yes, 16

No, 72

Prefer not to say, 12

Dependent caring responsibility (% of staff)


Do you have childcare responsibilities as a primary care giver (e.g. parent/guardian)?

Yes 30%

No 60%


Yes, 30

No, 60


Dependent caring responsibility (% of staff)


2.10 Sexual orientation

Hetrosexual/Straight, 77

Gay or Lesbian, 2

Bi-sexual, 2

Other, 1.3


Sexual orientation (% of staff)


2.11 Religion and belief % of staff

No religion 41%

Christian 38%

Jewish <1.3%

Muslim 1.3%

Any other religion 9%

Prefer not to say 16.9%

There were no responses for Buddhist; Hindu or Sikh faith categories

No religion, 41

Christian, 38

Jewish, 1.3

Muslim, 1.3

Any other religion, 9

Prefer not to say, 16.9

Religion and belief (% of staff)


2.12 Work patterns The ICO operates a system of flexible working hours which allows people to start work as early as 7.00am or as late as 10.30am; and finish work as early as 3.00pm or late as 7.00pm. There are currently 100 staff at the ICO who work part time. This represents around 22% of the workforce, which has been consistent over the last 12 months. There are 17 staff who work ‘compressed hours’ which allows them to work their contracted hours in fewer working days e.g. 37 hours in 4 days, or 74 hours in 9 days. Of these staff 9 are full time and 8 are part time. In total there are 58 different work patterns worked by ICO staff. Staff can apply to change their working hours for any reasons, including the care of children or dependents. The ICO has a procedure for dealing with such requests to ensure that they are handled fairly. 2.13 Career breaks The ICO allows staff to apply for a career break once they have completed two years of service. Career breaks can be taken for a number of reasons, including a break for the care and upbringing of children or the care of an adult dependent. Four staff are either currently on a career break or have taken a career break since December 2015.


2.14 Home working Many ICO staff are able to work at home for some of their working hours – this might be on a regular planned day of the week or on an ad hoc basis. Whilst staff are required to dedicate themselves to their work whilst they are at home, our homeworking provisions can help staff in a number of ways. For example, the removal of the need to commute every day may allow someone to be closer to child/dependent care provision and allow an earlier pick up. There are currently around 300 staff who have been provided with equipment to enable them to work outside the office at some time. 2.15 Reasonable adjustments The ICO has ‘reasonable adjustment’ policies for customers and staff. The customer policy is designed to enable disabled customers to use the ICO’s services if the standard processes prevent such access. The staff policy states how the ICO will make reasonable adjustments to work content, hours or the work environment to allow a disabled member of staff to work effectively, or to allow a member of staff who is or becomes disabled to remain in work. The ICO also makes adjustments for people who have short term health conditions, but are not disabled, to enable them to return to, or remain in, work. The ICO regularly makes adjustments to work patterns, the work environment or equipment to allow staff to continue to work. The organisation uses the advice of occupational health whenever appropriate. The Human Resources team have mapped the reasonable adjustments made for staff and held discussions with those who have adjustments to ensure that the support they have is adequate. Where further support needs have been identified, additional provisions have been put in place.


2.16 Equal Pay Analysis The ICO has eight pay grades, from job Levels A through to H, with Level A being the most junior position. Our pay system is designed to be fair and reflect the performance of individuals within their jobs. Almost all new staff start on the Entry Rate for their pay grade, and pay awards are made each year in line with government policy and following discussions with our trade unions. Staff who are promoted receive an increase of a minimum increase in salary of 10%, so staff who have been in their previous grade for several years may start their new job part way up the pay range. The table below sets out the average salaries of men and women in each pay grade, along with the average time of each gender in each grade. The final column shows the percentage pay differential between the genders. A positive percentage indicates the average salary is higher for women than men, and a negative percentage shows that the average is higher for men than women. The average salary for women in the ICO is £27,367. The average salary for men is £29,543. This represents a gap of 7.95%. This includes all staff, but not the Commissioner who is not employed by the ICO. The median salary for women is £24,911. The median salary for men is £24,911. A further breakdown of salaries by grade and gender is provided on the following pages.


Job Level A Proportion

of staff Average time in grade

Average pay

Average female vs

average male salary

Female 30% 18.4 yrs £16,667 - £17,177* +1.0% Male 70% 11.6 yrs £16,500 - £17,000*

Job Level B Proportion


Average pay

Average female vs

average male salary

Female 72% 3 yrs £18,346 -2.8% Male 28% 5.4 yrs £18,865 Job Level C

Proportion of staff

Average time in grade

Average pay

Average female vs

average male salary

Female 61% 3.3 yrs £20,108 +0.5% Male 39% 3 yrs £20,000 Job Level D Proportion


Average pay

Average female vs

average male salary

Female 64% 3.1 yrs £25,296 +0.14% Male 36% 2.5 yrs £25,260


Job Level E Proportion


Average pay

Average female vs

average male salary

Female 60% 4.9 yrs £32,070 -1.9% Male 40% 5.5 yrs £32,689 Job Level F Proportion


Average pay

Average female vs

average male salary

Female 55% 5.8 yrs £42,485 +2.6% Male 45% 4 yrs £41,377 Level G Proportion


Average pay

Average female vs

average male salary

Female 38% 2 yrs £49,500 - £50,000* -9% Male 62% 8.5 yrs £54,000 - £54,500*

* A range is given for data protection purposes because of the small number of staff in one or both categories. Information has not been provided for job level H as there are currently two men, but no women in this grade. Salary information regarding staff at this grade is published in the annual report in £5,000 ranges. The current average pay is in the range £80,000 - £85,000. Pay data does not include salaries of staff on protected or ‘red circled’ salaries. This arises when, for example because of a restructure, staff accept a lower graded post on their existing salary which is then frozen until the rate of pay for their new grade catches up with their salary rate.


Part 3: Information on services, policies and other functions: This section of the report is concerned with the services, policies and practices of the ICO and how, through the provision of those functions, we have endeavoured to meet our obligations under the Equality Act and enhance equality of opportunity in society. It is not intended to provide an exhaustive list of every action or activity that we take which helps to further equality of opportunity. Rather, this section of the report will provide an overview of how the ICO contributes to a more equal society, particularly through our remit as the regulator of information rights. Where helpful, we provide illustrative examples of the types of activity that are being delivered within key business areas. 3.1 Mainstreaming equality in the ICO The ICO is committed to ensuring that equality and diversity issues are considered as part of the planning and conduct of our activities. Our Corporate Plan includes equality and diversity dimensions that are integral to our core role as a regulator and enforcer of information rights. The plan and subsequent reports to our Management Board describe activity which improves awareness of information rights and access to our services. Our plans set out how the departments, working together where appropriate, will undertake actions which help individuals and organisations to be aware of their rights and obligations. Incorporated into these actions are commitments to build in equality considerations when extending our reach. This means that the ICO’s leaders have accountability for the fulfilment of the work we have set out in our plans with equality considerations integrated into our work and core activities.


The two over-arching organisational equality objectives detailed in the first part of this report help all staff understand that the ICO has both internal and external responsibilities and to consider opportunities for improvement in these areas. 3.2 Supporting mainstreaming through the Equality and Diversity Committee. The Equality and Diversity Committee is chaired by two members of the Senior Management Team and its membership is published on ICON, the staff intranet, where key equality and diversity messages are also published. The Senior Management Team (SMT) is also made aware of key issues raised by the Equality and Diversity Committee. The Committee meets 6-8 times a year and as well as addressing topical issues has a rolling structure of business that includes: strategic review of equality and diversity elements of the draft business plan, 6-monthly monitoring of progress against organisational equality objectives, organisational improvement, good practice development sessions and proactive internal communication around equalities. 3.3 Leadership The Chairs of the Equality and Diversity Committee report progress directly into the SMT on a regular basis as well as ‘championing’ equality issues elsewhere within the organisational structure. The Commissioner and other members of the SMT have actively participated in development and training sessions on equality and engaged closely with the specific progress of the ICO against its equality maturity model. Senior figures across the organisation provide proactive and positive communication on equalities issues, for example during team and department meetings.


Information about the characteristics and make-up of the ICO’s staff is provided to the Management Board on a quarterly basis. 3.4 Ensuring staff are trained in equality issues Training, both formal and informal, is a key contributor to the delivery of many aspects of the ICO Corporate and Business plan and fundamental to the delivery of the organisational equality objectives. The ICO places considerable value in ensuring that staff receive the necessary training so that they can develop skills and understanding of their roles in line with the aims and objectives of the ICO. There has been a significant amount of training and awareness sessions which have an equality dimension in recent years, including ‘Dignity, Diversity and Inclusion’ training which is mandated for all new staff, ‘Autism and Asperger’s Awareness’, and Building Equality into Business Planning. These sessions help to improve awareness of matters that affect our customer group, as well as ensuring that staff are fully versed in the organisation’s commitment to fairness, equality and dignity in our dealings with each other. 3.5 Communicating the ICO’s strategy The ICO takes the view that good communication is essential to the delivery of the Corporate Plan and the organisational equality objectives. The key principles that underpin effective communication and ensure consideration of diversity and inclusiveness are set out as follows: • Good communication is defined as two-way, appropriate to

the audience, medium and message, and is in correct, clear language.


• Good communication is honest, relevant, timely, appropriate, useful, inclusive and authoritative.

• Good communication can also be persuasive. • Good communication is tailored to suit the audience. Our Strategic Liaison department continues targeted outreach work to improve engagement with charities, umbrella groups and sponsor bodies that have a ‘second tier’ function – in other words, those that in turn reach out and support other organisations to improve understanding and practice. This has been planned to help provide additional support to, for example, older people who have significant concerns and issues around information rights and data protection but who may not always easily access the ICO’s core services. 3.6 Monitoring and evaluating equality data.

Collecting information to help understand the needs and issues relating to the diversity of staff and customers is important when monitoring progress towards the ICO’s over-arching equality objectives.

The ICO collects a wide range of data from staff monitoring and surveys and some more limited data from customers.

Customer satisfaction surveys measure a range of issues to do with our performance and customer handling.

We continue to monitor recruitment processes to ensure that they are conducted fairly and encourage applications from across the whole community. 3.7 Ensuring that staff and customers can access information and services. Accessibility of information is specifically addressed within the ICO Corporate Affairs strategy and is recognised as being key


to achieving both our internal and external equality objectives. The strategy establishes the principles of inclusiveness that incorporate the provisions of the Equality Act, Northern Ireland legislative requirements, and the Welsh language requirements. The ICO website meets AAA accessibility standards wherever possible (the government requires AA status). This means, for example, that text size can be altered and a browsealoud facility is available. This functionality has been improved in the last twelve months. All publications are produced to accessibility standards and the corporate “Style Guide” also incorporates this good practice. For example all ICO publications: use sans serif fonts for core text;

use a font size of 12 point minimum and 14 points for important information;

maximise white space

use a dark out of white colour scheme

use good quality matt paper to reduce glare and the text showing through from the other side.

The ICO also trains staff to write in plain English and has produced a “Style Guide”. The ICO: limits sentences to between 15 – 20 words;

avoids dense block text paragraphs;

uses line spacing between paragraph breaks;

keeps lines left justified with a ragged right edge;


uses bullets or numbers rather than continuous prose; uses fact boxes to make main point clear;

uses images where possible to support text; and

seeks accreditation by the ‘Plain Language Commission’

for key leaflets and guidance. The ICO has a Translations Policy that covers the publications and correspondence it produces. The policy states that, on request, the ICO will arrange for written information to be made available in Braille or on tape for blind or visually impaired users. The ICO Welsh Language Scheme outlines the criteria used to decide which ICO publications need to be available in Welsh. We have responded to the Welsh Language Commissioner’s standards investigation, and are waiting to hear which of the proposed standards will apply to the ICO. We do not have the budget to undertake translation of all publications as a matter of course, but we will respond to individual requests in line with our Translations Policy, which can be found on our website. We have a duty to manage our funds effectively and make sure that our resources are allocated in a way that maximises impact in a proportionate manner. Our operational procedures establish approaches both for handling customers with particular needs and making ‘reasonable adjustments’ as defined within equality legislation. In relation to learning and development, flexible options are built in covering timing of events, location, format of materials and method of delivery.


The ICO also ensures that work related events, and any refreshments served there, are inclusive as possible taking particular account of religion or belief. In addition to these long standing arrangements, the ICO has introduced ‘live chat’ services which enable members of the public to interact with the organisation online. This has promoted accessibility for those who may feel anxious using the telephone helpline service, or perhaps have hearing impairments which could be a barrier to using the service. The ICO’s helpline service was been subject to a ‘mystery shopper’ survey in the early part of 2016 by an independent research organisation and was found to have a 93% approval rating.


Appendix 1 – Equality objectives linked to Corporate Plan and organisational measurement frameworks

Corporate equality objective 1 (external)

To extend the ICO’s external reach so that a wider range of individual and organisational users are aware of, and able to access our services

This means …. The ICO reaching out to different people with an approach that is relevant and accessible It links directly to the following organisational strategic outcomes / objectives 2015-18

1. Having a high proportion of individuals with a basic awareness of their information rights, coupled with ready access to information on how to exercise those rights

2. Development of people’s understanding of information rights and risks embedded as an output of the formal education system

This takes into account our equality principles ….

• Contribution: What we do contributes to our core purpose of upholding information rights. • Fairness: We achieve greater fairness in information rights and in how the ICO operates. • Reach: Our practices and information rights activity meets the needs of more people • Proportionality: Actions are proportionate with an effective use of resources that balances input required and

desired outcomes We target this by ……. Identifying business critical areas where we believe the interests of particular groups are under-represented

Identifying areas of existing demand where we need to adapt or amend our approach for an improved outcome We measure this by ….. Analysing the quantitative and qualitative responses to our initiatives

Stakeholder perception survey and annual track analysis Conducting focus groups and survey-based research

The types of activities that deliver this include ….

- Good Practice Team developing a programme of advisory visits with 2nd tier equality organisations in the third sector

- Developing a policy and procedure concerning the handling of Gender Recognition Certificates. - Responding to consultations from other public sector organisations to ensure that information rights considerations

have been taken into account in their plans. - Strategic Liaison team’s participation in the Creative Diversity Network established by Channel 4. - Introduction of Live Chat as an alternative mechanism for engaging with the ICO’s helpline.


Corporate equality objective 2 (internal)

To mainstream equality understanding and skills within our workforce in order to improve employee experience and our capacity to meet diverse user needs

This means …. Building the equality and diversity skills of our people so that it is a better place to work and so we can effectively widen the reach and impact of ICO

It links directly to the following organisational strategic outcomes / objectives 2015-18

1. Customers receive a proportionate, fair and efficient response to their information rights concerns. 2. Individuals are empowered to use their information rights. 3. The ICO is alert and responsive to changes which impact on information rights. 4. ICO is an efficient organisation well prepared for the future.

This takes into account our equality principles ….

• Contribution: What we do contributes to our core purpose of upholding information rights. • Fairness: We achieve greater fairness in information rights and in how the ICO operates. • Reach: Our practices and information rights activity meets the needs of more people • Proportionality: Actions are proportionate with an effective use of resources that balances input required and

desired outcomes We target this by ….. Identifying where training and development can best support existing need or opportunity – for example our

continuing programme of Asperger’s and Autism awareness training for staff Identifying any remedial action that needs taking in relation to any staff complaints, grievances or Dignity at Work

cases We measure this by ….. Training needs analysis and participation rates in development activities

Staff questionnaires and annual staff satisfaction surveys Performance and development reviews

The types of activities that deliver this include ….

- First Contact reasonable adjustment and customer service reviews - Collation of equality actions and outcomes from operational departments - Policy Delivery guidance concerning data protection for trans-gender people. - ‘Mainstreaming’ of equality and diversity initiatives into operational plans. - ‘Adjustment mapping’ of the arrangements in place to enable disabled colleagues to work effectively and

comfortably.


Appendix 2: Specific equality based actions within the ICO Corporate Plan

Corporate Plan objective

Description

1.2 Providing practical and helpful advice to organisations both by telephone and in writing; using staff committed to good customer service who are focused on customer needs.

1.5 Promoting good information rights practice through a programme of audits, advisory visits, workshops and the continuous development of the self-assessment tool for organisations.

1.7 Considering how best to identify and act on opportunities to work with other organisations to extend the reach of our guidance; with particular reference to changes under the EU data protection reforms.

4.1 Providing practical and helpful advice to the public both via the telephone and in writing; using staff committed to good customer service and focused on customer needs.

4.2 Providing the public with advice about new threats to the security of their information (eg viruses) and the steps they can take to protect themselves.

4.3 Reviewing the nature of the advice we provide for individuals, and who it is directed at, to ensure we are as effective as possible in helping to protect and empower both adults and children.

4.7 Working with organisations, including those concerned with online child safety, to maximise the impact of guidance on how individuals can protect themselves against information rights risks.

4.8 Extending the ICO’s reach into all parts of the country and sections of society to achieve equality of access to information rights and our services.

4.5 Extending the ICO’s reach into all parts of the country and sections of society to achieve equality of access to information rights and our services

6.8 Embedding diversity and our values so that they are an everyday part of how we work and of our decision making


Appendix 3: Examples equality of actions and outputs in the last year

Summary of Action Taken Business and E&D Impact Groups most

benefitting from the action

The ICO operates a ‘Two Ticks’ standard or guaranteed interviews for disabled job applicants who meet the minimum criteria for the job.

Encourages a diversity of experience in the workforce and improves accessibility of job opportunities to disabled people.

Disabled people

We provide a wide range of adjustments for staff. An exercise to map these adjustments made was undertaken, with a review with individuals of their needs to ensure that an accessible work environment is provided.

Ensuring that disabled staff, and those with shorter term health conditions, are able to work comfortably and have the equipment and work arrangements needed to work effectively.

Disabled staff and staff with health conditions.

We have installed an accessible toilet in part of our building where there was not one previously.

Providing equal access to building facilities and improving convenience for all staff.

Disabled staff and those with difficulties accessing facilities elsewhere in the building.

We provide learning materials in a variety of formats to meet the needs of staff undertaking training.

Ensures that all staff are able to fully access training and equally able to benefit from the desired learning outcomes.

Staff with varying learning styles or who have disabilities such as visual impairments or dyslexia


We have implemented a Live Chat online service for our helpline. This enables customers to access our services in a new way, and is of potential benefit to hearing impaired customers.

Enables customers to contact via a wider range of methods and improves accessibility of our services.

All customers who have difficulties with, or prefer not to have, telephone interactions.

We make adjustments to the way we provide services to customers who are otherwise unable to access our services.

Improvements to the services to all customers and promotion of accessibility of information rights.

Disabled people and others for whom access to our services may be difficult.

We held a well-being week for staff which incorporated a range of activities including the promotion of networks for carers.

Improving staff welfare and awareness of support.

ICO staff, particularly those with caring responsibilities.

We ran a series of workshops aimed at local government children's services with the aim of improving Data Protection Act compliance and safeguarding vulnerable data subjects

Improving Data Protection compliance in the public sector, particularly for those working with children and vulnerable people.

Children and families

We have investigated cases concerning the disclosure of information relating to gender reassignment, ethnicity, sexual orientation and disability amongst others.

Providing protection for people who have very sensitive personal data held by organisations. Helping to improve compliance with the law.

A range of groups across society.


Our enforcement action emphasises the importance of ensuring the security of such sensitive data.

Our Enforcement department’s communications with suspects, data subjects and witnesses refer to reasonable adjustments which can be made so that interviews can be conducted in a manner which is fair and accessible for all.

Ensuring that the action that we take provides fair access or exposure to our enforcement processes which is accessible to all.

Disabled people

The Enforcement department participated in the Citizens Advice led ‘Scams Awareness Month’ (July 2016) to improve consumer awareness of fraud, scams and use of personal data.

Enforcement joint-working with other regulators/agencies.

Consumers without internet access. Older, isolated and vulnerable people.

Participation in Trading Standards Scotland-led ‘Week of Action’ targeting vulnerable members of society in Scotland and driving Telephone Preference Service take-up.

Protection of vulnerable data subjects. Enforcement joint-working with other regulators/agencies.

The week of action was targeted in Scotland, as evidence shows that region receives the highest proportion of nuisance calls.


Memorandum of Understanding agreed with Charity Commission and in discussion with Fundraising Regulator.

Protection of vulnerable data subjects. Enforcement joint-working with other regulators/agencies.

Older, isolated and vulnerable people targeted by fund raisers.

All staff within Performance Improvement Department mandated to attend Mental Health Awareness, Autism and Asperger Syndrome training. This training was also available to all staff in the ICO.

Improved customer service and understanding of these conditions and the potential needs which may result.

Customers, staff

Issues arising out of our casework which identify an organisation is not taking adequate steps to address an individual's disability are flagged up to the organisation For example, this resulted in a government department updating its policy to allow people with visual impairments to make an FOI request verbally instead of in writing.

Reduction in complaints to ICO about those organisations we deal with in relation to equality issues. Improved customer service experience of ICO's remit.

Customers and the external organisations with whom we work.

Improved clarity within Performance Improvement department about what reasonable adjustments may entail and how we can anticipate them.

Assurance that customers who require reasonable adjustments to access our services are treated fairly.

Customers, staff


Improved understanding of info rights amongst focus groups

Homeless

Participation in round table discussion on financial harm and older persons


Older people

Advice in relation to mobile device application focused on residents of conflict related areas in Northern Ireland

Security of application for vulnerable people in troubled areas

Local residents (Age, religion, political beliefs, criminal history)

Running a series of #datafriday data protection focussed workshops in Northern Ireland

Raised awareness of Data Protection issues in the voluntary sector

Clients of voluntary organisations

Consultation response to Lifeline Crisis Support Service

Raising awareness of Data Protection with public sector policy makers

Various vulnerable groups


Series of workshops held with community groups.


Mental Health groups Vulnerable women

Participation in Belfast Pride Raised awareness of ICO in LBGT+ community

LBGT+ community

Working with survivors of care (often with mental or physical health issues) to provide advice and guidance on exercising subject access rights for their social work records

Awareness of Subject Access rights Vulnerable adults and care leavers

Provided advice and guidance regarding confidential information being disclosed in civil cases contrary to the rights of the child

Increased awareness of DP compliance Children and parents/carers

Working with vulnerable groups in the Angus region of Scotland.

Increased awareness of info rights Vulnerable adults

Provision of advice and guidance to religious groups

Increased Data Protection compliance Members of those religious communities.


Consultation response on Mental Health Act 1983 Code of Practice for Wales

Improved compliance by bodies following the CoP

People suffering from Mental Health issues

Workshops with pre-school providers across Wales

Improved practice by providers Pre-School Providers and their data subjects

Partner in the Wales Against Scams Partnership

Improved awareness of Privacy and Electronic Communications Regulations.

Vulnerable groups (particularly older people and younger age, those mental health issues and people who have learning difficulties)

Response to Welsh Government consultation on "Supporting Learners with Healthcare Needs"

Improved practice by providers Learners with healthcare needs

Working with Careers Wales, the Welsh Government and NHS Wales to improve Information Governance practices

Improved compliance by public bodies Young people, transgender people, vulnerable adults.

Documents

Annual Equality Information Publication...ICO Equality Duty Annual Information Report, December 2016, v1 Page 2 of 37 Part 1: Introduction to the ICO and this report About the ICO