Agenda Document Pack - Scrutiny and Performance Committee - 13/09/2023
Perth and Kinross Council · 13 September 2023
Back to Scrutiny and Performance Committee — 13 September 2023 and its agenda
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ExemptExempt Securing the future… • Improving services • Enhancing quality of life • Making the best use of public resources Council Building 2 High Street Perth PH1 5PH 07/09/2023 A hybrid meeting of the Scrutiny and Performance Committee will be held in the Council Chamber on Wednesday, 13 September 2023 at 10:00. If you have any queries please contact Committee Services on (01738) 475000 or email Committee@pkc.gov.uk. THOMAS GLEN Chief Executive Those attending the meeting are requested to ensure that all notifications are silent on their device and other devices are in silent mode. Please note that the meeting will be broadcast online and recorded. The recording will be publicly available on the Council’s website following the meeting. Members: Councillor Colin Stewart (Convener) Bailie Alasdair Bailey (Vice-Convener) Councillor Keith Allan Councillor Steven Carr Councillor Eric Drysdale Councillor Angus Forbes Councillor Ian Massie Councillor Willie Robertson Councillor Caroline Shiers Councillor Frank Smith Councillor Jack Welch Page 1 of 98
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ExemptExempt Scrutiny and Performance Committee Wednesday, 13 September 2023 AGENDA MEMBERS ARE REMINDED OF THEIR OBLIGATION TO DECLARE ANY FINANCIAL OR NON-FINANCIAL INTEREST WHICH THEY MAY HAVE IN ANY ITEM ON THIS AGENDA IN ACCORDANCE WITH THE COUNCILLORS’ CODE OF CONDUCT. 1 WELCOME AND APOLOGIES 2 DECLARATIONS OF INTEREST 3 MINUTE OF MEETING OF THE SCRUTINY AND PERFORMANCE COMMITTEE OF 7 JUNE 2023 FOR APPROVAL (copy herewith) 5 - 10 4 OUTSTANDING BUSINESS STATEMENT (copy herewith) 11 - 14 5 PERTH AND KINROSS COUNCIL ANNUAL PERFORMANCE REPORT 2022/23 Report by Chief Executive (copy herewith 23/234) 15 - 76 6 FOI PERFORMANCE REPORT 2022-23 Report by Head of Legal and Governance Services (copy herewith 23/246) 77 - 84 7 DATA PROTECTION COMPLIANCE 2022-23 Report by Head of Legal and Governance Services (copy herewith 23/247) 85 - 98 IT IS RECOMMENDED THAT THE PUBLIC AND PRESS SHOULD BE EXCLUDED DURING CONSIDERATION OF THE FOLLOWING ITEM(S) IN ORDER TO AVOID THE DISCLOSURE OF INFORMATION WHICH IS EXEMPT IN TERMS OF SCHEDULE 7A TO THE LOCAL GOVERNMENT (SCOTLAND) ACT 1973 P1 APPENDIX TO MINUTE OF THE SCRUTINY AND PERFORMANCE COMMITTEE OF 7 JUNE 2023 Page 3 of 98
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Exempt SCRUTINY AND PERFORMANCE COMMITTEE Minute of hybrid meeting of the Scrutiny and Performance Committee held in the Council Chambers, 2 High Street, Perth, on Wednesday 7 June 2023 at 10.00am. Present: Councillor C Stewart, Bailie A Bailey, Councillors K Allan, B Brawn (substituting for Councillor A Forbes), S Carr, E Drysdale, A Forbes, I Massie, W Robertson, F Smith, and J Welch. In Attendance: K Donaldson (Chief Operating Officer), B Renton (Executive Director, Communities); S Devlin (Executive Director, Education and Children’s Services); C Mailer (Executive Lead - Strategic Planning and Transformation) C Guild, G Pinfield, E Ritchie and F Robertson (Communities), S Cooper, G Doogan, S Johnston and B Scott (Education and Children’s Services), M Dickson and K Ogilvy (Health and Social Care Partnership); and L Simpson, S Crawford, P Johnstone, L Harris, K Molley, A Brown and R Ramsay (all Corporate and Democratic Services). Apology: Councillor A Forbes Councillor C Stewart, Convener, Presiding. The Convener led discussion on Items 1- 7 and P1 and the Vice-Convener led discussion on items 8-10. 1. WELCOME AND APOLOGIES The Convener welcomed all those present to the meeting and an apology was noted above. 2. DECLARATIONS OF INTEREST No declarations of interest were made in terms of the Councillors’ Code of Conduct. 3. MINUTE OF MEETING OF THE SCRUTINY AND PERFORMANCE COMMITTEE OF 26 APRIL 2023 The minute of meeting of the Scrutiny and Performance Committee of 26 April 2023 was submitted and approved as a correct record. 4. OUTSTANDING BUSINESS STATEMENT Resolved: The status of actions in the Outstanding Business Statement, be noted and completed actions removed accordingly. 5. PERFORMANCE AND IMPROVEMENT PLANNING G Guild, Head on Innovation, provided a short slide-based presentation highlighting the change in performance reporting and improvement planning in 2023/24. 3 Page 5 of 98
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Exempt 6. SERVICE ANNUAL PERFORMANCE REPORT 2022/23 – CORPORATE & DEMOCRATIC SERVICES There was submitted a report by Executive Director (Education and Children’s Services) (23/175) presenting the Service Annual Performance Report (APR) 2022/23 for Corporate and Democratic Services (CDS); and (2) detailing progress over the last year against improvement actions contained within the 2022/23 Service Business Management Improvement Plan (BMIP). In response to a question from Councillor C Stewart regarding the reduction in energy consumption this year, S Crawford advised that over the last year Property Services had focused on large building audits. S Crawford thanked Business Managers and Headteachers who had helped in monitoring and using less energy across schools in Perth and Kinross. S Crawford confirmed that this year had been marginally warmer than previous years which had helped. S Crawford advised that the percentages in reduction of consumption this year form part a ten-year ongoing reduction project in Perth and Kinross Council. In response to a question from Bailie A Bailey regarding sickness absences for employees and if the average of 13 days reflects pre-covid levels, P Johnstone advised that the sickness levels for 2019/20 would be shared with members following committee. P Johnstone confirmed that cases of Covid stopped being recorded in January 2023 and only notifiable infectious diseases were recorded from July 2022 onwards which had an impact on the sickness levels increasing in terms of short-term absences. P Johnstone added that in terms of sickness absence levels it is difficult to determine who is a hybrid employee and who is working from home as data is not recorded. However, P Johnstone confirmed that HR would undertake further analysis to establish the types of roles those sickness absences are in. In response to a question from Councillor K Allan regarding the pilot of the Microsoft Chatbot in Perth and Kinross Council, L Harris confirmed that in terms of improving customer experience, it is vital to have consultation with employees. L Harris added that employee consultation would allow for appropriate testing to be undertaken to ensure that the Chatbot function is fit for purpose before being rolled out across the organisation. In response to a question from Councillor W Robertson regarding the devolved decision-making pilot for the Kinross-shire Area, the Convener confirmed that the three areas that agreed to undergo a devolved decision-making process as part of the budget process, would be formed by the outcomes, lessons learned and continuous improvement of the Kinross-shire pilot. In response to a question from Councillor I Massie regarding sickness absence levels amongst teachers, P Johnstone advised that 8.9 days is per head count of the teacher population. P Johnstone confirmed that details on short-term, medium-term, and long-term absences of the teaching population would be provided following committee. In response to a question from Councillor F Smith regarding teacher sickness absences caused by disruption of pupils, P Johnstone advised that new arrangements are in place to report and monitor levels of violence and aggression by pupils. Page 6 of 98
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Exempt In response to a question from Councillor C Shiers regarding the availability of comparative data on sickness absence levels to benchmark with other Local Authorities, K Donaldson advised that timing had been a factor and information would be published formally through the Local Government Benchmarking Framework later in the year. Members thanked officers for their work in preparing the Corporate and Democratic Services Annual Performance Report. Resolved: The contents of the Corporate and Democratic Services’ Annual Performance Report 2022/23, be scrutinised. 7. COMMUNITIES SERVICE ANNUAL PERFORMANCE REPORT 2022/23 There was submitted a report by Executive Director (Communities) (23/181) presenting the Service Annual Performance Report 2022/23 for Communities; and (2) detailing progress against targets and improvement actions over the last year against the 2022/23 Service Business Management Improvement Plan. In resposne to a question from Councillor K Allan regarding tackling inequalities across Perth and Kinross, B Renton confirmed that the Community Planning Partnership agreed to focus on two areas – Coupar Angus and Crieff, but Perth and Kinross Council are committed to tackling inequalities and poverty across all areas in Perth and Kinross. C Mailer added that several locality-based projects are also underway including in areas of Letham and Highland Perthshire. C Mailer advised that Perth and Kinross Council have recently initiated a data discovery project which involves mapping poverty and inequalities across all localities to ensure targeted work can be achieved. Councillor C Shiers raised concerns over individuals in rural areas in Perth and Kinross not having adequate access to broadband provision. G Pinfield sympathised with individuals’ frustrations but confirmed that Perth and Kinross Council have bid into the UK Government Programme for the Local Full Fibre Network to help reach properties with connection struggles. G Pinfield confirmed that work had also been underway with Open Reach to target properties in difficult terrain and to encourage overspill into premises off the main contract. In response to a question from Councillor I Massie regarding support offered to tenants suffering with mould and damp, E Ritchie advised that the Housing Service have developed a robust procedure which offers advice and assistance to tenants who struggle with mould and damp in their premises. E Ritchie added that initially, the property would be investigated to see the appropriate course of action to be taken as the mould could be a result of many factors such as ventilation issues or improvement works needing carried out. E Ritchie confirmed that an Elected Member Briefing Note had been circulated regarding the Councill’s position and would be recirculated in due course with up-to-date information. In response to a question from Councillor C Shiers regarding footfall in small towns out with Perth City Centre, B Renton advised that an update would be provided following Committee. Page 7 of 98
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Exempt In response to a question from Councillor E Drysdale regarding challenges of recruitment and retention of staff, P Johnstone advised that there had been a shortage nationally of employees in particular roles and work had been underway across the organisation to help retain and attract employees through career fairs and promoting posts on social media, emphasizing the benefits of working and living in Perth and Kinross. P Johnstone added that hybrid opportunities are also available. In response to a supplementary question from Councillor E Drysdale regarding the relationship between Perth and Kinross Council and Skills Development Scotland (SDS), P Johnstone advised that the Council does work closely with SDS in terms of promoting opportunities, economic development, long term unemployed schemes and modern apprenticeships. Members thanked officers for their work in preparing the Communities Annual Performance Report. Resolved: The contents of the Communities Service Annual Performance report 2022/23, be scrutinised. THERE WAS A SHORT RECESS AND THE MEETING RECONVENED AT 11.20AM. 8. EDUCATION AND CHIDLREN’S SERVICES ANNUAL PERFOMANCE REPORT 2022/23 There was submitted a report by Executive Director (Education and Children’s Services) (23/181) presenting the Service Annual Performance Report (APR) 2022/23 for Education and Children’s Services; and (2) detailing progress against targets and improvement actions over the last year against the 2022/23 Service Business Management Improvement Plan (BMIP). As part of her opening remarks, S Devlin advised that data on the achievement of Curriculum for Excellence 2019/20 would be circulated to members following Committee. S Devlin confirmed that the reason it was not originally included in the Annual Performance Report had been due to the data being incomplete. The direction from the Scottish Government at the time was that gathering and the submission of data was not required due to pressures of the pandemic. In response to a question from Councillor I Massie regarding the new electronic tracking system to monitor children’s progress in early learning centre settings, B Scott advised data gathered would not be shared with parents but reassured members that parents are kept well informed about their child’s progress through other processes. B Scott confirmed that some settings have physical children’s profiles that children can share with their parents. In response to a question from Councillor C Shiers regarding work being undertaken to improve children’s attendance across Perth and Kinross schools, S Johnston advised that challenges regarding attendance had risen following the pandemic, with a range of issues varying from children feeling too anxious to attend school or children that attend school in the morning but do not turn up to all classes throughout the day. S Johnston confirmed that there are ongoing projects to look at emotionally based absences and support children with mental health issues. S Johnston advised that through staffing arrangements, Pupil Care and Welfare Page 8 of 98
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Exempt Officers have been introduced into Secondary Schools and Community Link Assistants in Primary Schools to support child attendance. S Johnston added that attendance had been a national issue and work had been underway with other Local Authorities to analyse best practice and see what more could be done in improving child attendance across schools. In response to a supplementary question from Councillor C Shiers regarding recording the reasons for a child’s absence, S Johnston advised that as well as recording absences through the system SEEMIS, Quality Improvement Officers have quarterly meetings with senior staff to discuss that school’s attendance data. Attendance rates are gathered and any child that has below 80% rate should be actioned and monitored. In response to a question from Councillor W Robertson regarding the Curriculum for Excellence and the performance of Perth and Kinross Council, S Devlin confirmed that through the Quality Improvement Framework, Education and Children’s Services work with Headteachers across schools in Perth and Kinross to monitor the quality of learning and teaching in every classroom to ensure it is the best it can be. In response to a question from Councillor C Stewart regarding instances where exclusion from school is the appropriate solution for a child demonstrating challenging or violent behaviour, S Devlin confirmed that alternative measures to discipline a child are preferred over the use of exclusion, however, the Exclusion Guidance can permit exclusion to the appropriate measure based on the context of the situation and to benefit the young person involved and others around them. In response to a supplementary question from Councillor C Stewart, S Johnston advised that a quick and simple electronic recording system had been created to allow staff to able to record incidents of behaviour as they happen. Incidents that are recorded are sent to the Quality Improvement Officer Team who track the data to see if there is a pattern in behaviour from the same child and if intervention measures are required. If multiple incidents arise for the same child, then a discussion would be held with the school to see if further support could be provided to the child without having to use exclusion. In response to a question from Councillor E Drysdale regarding work being undertaken to reduce the attainment gap of literacy and numeracy throughout primary schools, G Doogan advised that levels of improvement in reducing the attainment gap had been shown across all ages but confirmed that there had been a significant development at stage Primary 4 due to targeted work. G Doogan confirmed that Education and Children’s Services are in the process of gathering data for 2022/23 and early indications are positive. S Johnston added that even though there had been levels of improvement, children who are most disadvantaged within Perth and Kinross continue to improve less well than those who are least disadvantaged. S Johnston confirmed that work continues to improve the gap for all children. In response to a question from Councillor J Welch regarding actions plan in place to improve areas of free school meal uptake, S Devlin advised that work had been underway across schools in Perth and Kinross and secondary young people had participated in a national survey regarding school meal preferences. S Devlin added that results highlighted that secondary young people least preferred the option of a sit- down lunch in a large school hall and favoured the option of a grab and go type facility. S Devlin confirmed that grab and go facilities had increased within schools but with other grab and go facilities available out with the school premises, it had been difficult Page 9 of 98
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Exempt to encourage young people who are entitled to a free school meal to take them. S Devlin highlighted the importance in improving the dining experience in line with the feedback received from young people. In response to a supplementary question from Bailie A Bailey regarding the number of pupils in secondary schools who are eligible for free school meals but choose not to take them, S Devlin advised that data would be circulated following Committee. Members thanked officers for their work in preparing the Education and Children’s Services Annual Report. Resolved: The contents of the Education and Children’s Services Annual Performance report 2022/23, be scrutinised. 9. ANNUAL GOVERNANCE STATEMENT There was submitted a report by Head of Legal and Governance Services (23/182) presenting for scrutiny and review, the draft Annual Governance Statement (AGS) for the financial year 2022/23 which provides assurance as to the effectiveness of the Council’s governance framework and, in particular, the system of internal control. Resolved: (i) The contents of the draft Annual Governance Statement for the financial year 2022/23, be scrutinised. (ii) The assurance provided as to the adequacy and effectiveness of the Council’s governance arrangements including the system of internal control, be noted. 10. PERTH AND KINROSS HEALTH AND SOCIAL CARE PARTNERSHIP CLINICAL AND CARE GOVERNANCE ASSURANCE REPORT There was submitted a report by Chief Officer, Perth and Kinross Health and Social Care Partnership providing assurance on the Clinical Care and Professional Governance of the Perth and Kinross Health and Social Care Partnership. Resolved: The contents of Report 23/179, be noted. IT WAS AGREED THAT THE PUBLIC AND PRESS SHOULD BE EXCLUDED DURING CONSIDERATION OF THE FOLLOWING ITEMS IN ORDER TO AVOID THE DISCLOSURE OF INFORMATION WHICH IS EXEMPT IN TERMS OF S30 OF THE FREEDOM OF INFORMATION (S) ACT 2002 P1. ANNUAL REVIEW OF CYBER SECURITY There was submitted a report by Head of Legal and Governance Services (23/180) providing an overview of the Council’s cyber security arrangements and provide assurance as to the management and mitigation of relevant risks and threats. Resolved: (i) The contents of Report 23/180, be scrutinised. (ii) The assurance as regards the adequacy and effectiveness of the Council’s cyber risk and management arrangements, be noted. Page 10 of 98
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Exempt SCRUTINY AND PERFORMANCE COMMITTEE OUTSTANDING BUSINESS STATEMENT (OBS) Please note that this statement sets out outstanding decisions of this committee along with an update and estimated completion date. Actions which are overdue are shaded for ease of reference. Where an update reflects that an action is complete then the Committee’s agreement will be sought to its removal from the OBS. No Minute Reference Subject Title Outstanding Action Update Lead Officer /Service Action due Action Expected 6. 6 June 2022. Item 6(d). Closing out of Improvement Actions from BMIPS. Methodology to be constructed in terms of closing out of Improvement Actions raised in BMIPS. Development Session was arranged in May 2023 for members on the new Improvement Service Local Government Benchmarking Framework dashboard. Elected Member Briefing Note was issued last week on the changes to reporting process this year. Short presentation to be deliver to Committee on the process of moving away from BMIPs. COMPLETED All services 7 June 2023 7 June 2023 4 Page 11 of 98
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Exempt No Minute Reference Subject Title Outstanding Action Update Lead Officer /Service Action due Action Expected 14. 26 April 2023 Item 7 Perth and Kinross Health and Social Care Partnership (HSCP) Clinical and Care Governance Assurance Report A briefing session to be arranged for all members on how the Health and Social Care Partnership Operates Still working with officers on a suitable date to hold a briefing session. NOT COMPLETED Jacquie Pepper/Lisa Simpson TBC TBC 15. February 2023 Scrutiny Review Topics Progress with discussions on Additional Support Needs Provision in Perth and Kinross Initial meeting was held with officers and Convener/Vice- Convener. A follow up meeting was arranged with Officers and the Convener/Vice- Convener. The Convener/Vice- Convener are meeting with officers to discuss the ASN presentation that was presented to the Transformation Board. NOT COMPLETED Education and Children’s Services/ Legal and Governance Services TBC TBC 16. 7 June 2023 Item 5 Service Annual Performance Report 2022/23 – Corporate and Democratic Services Provide data on sickness absences for 2019/20 to committee members. Provide details on short- term, medium-term and long-term sickness absences for teachers. Elected Member Briefing note was issued. COMPLETED Human Resources 13 September 2023 13 September 2023 Page 12 of 98
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Exempt No Minute Reference Subject Title Outstanding Action Update Lead Officer /Service Action due Action Expected 17. 7 June 2023 Item 6 Communities Service Annual Performance Report An update to be provided on footfall in small towns out with Perth City Centre. Email response to be issued to Members. TO BE COMPLETE Communities 13 September 2023 13 September 2023 18. 7 June 2023 Item 7 Education and Children’s Services Annual Performance Report Provide data on the Achievement of Curriculum for Excellence Levels for 2019/20 to members. Information was emailed to members following committee. COMPLETED Education and Children’s Services 13 September 2023 13 September 2023 19. 7 June 2023 Item 7 Education and Children’s Services Annual Performance Report Provide data on the current levels of uptake of Free School Meals (FSM) in primary and secondary schools within Perth and Kinross. Information was emailed to members following committee. COMPLETED Education and Children’s Services 13 September 2023 13 September 2023 Page 13 of 98
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Exempt PERTH AND KINROSS COUNCIL Council – 30 August 2023 Scrutiny and Performance Committee – 13 September 2023 PERTH & KINROSS COUNCIL ANNUAL PERFORMANCE REPORT 2022/23 Report by the Chief Executive (Report No. 23/234) 1. PURPOSE 1.1 The Annual Performance Report (APR) is part of the Council’s strategic planning and performance framework, supporting delivery of the Council vision and achievement of outcomes. It provides an overview of how we have performed against our priorities, actions and associated key performance indicators in the period from April 2022 to March 2023, as set out within our Corporate Plan 2022-2027. 1.2 This is a transitional year as we are reporting on performance during a year in which Council approved a new Corporate Plan. Whilst the revised Corporate Plan was approved by Council in December 2022, this report covers a full financial year reporting period. It recognises activity undertaken in support of our corporate priorities both pre-and post publication of the Plan. 2. RECOMMENDATION 2.1 It is recommended that the Council: • approves the Annual Performance Report for 2022/23. It is recommended that Scrutiny and Performance Committee • scrutinises the Annual Performance Report for 2022/23. 3. STRUCTURE OF REPORT 3.1 This report is structured over the following sections: • Section 4: Background • Section 5: Summary Information • Appendix 1: Perth and Kinross Council Annual Performance Report 2022/23 • Appendix 2: Annual Performance Report 2022/23 Executive Summary 4. BACKGROUND 4.1 Perth and Kinross Council’s Annual Performance Report (APR) is a statement of the progress made towards achieving our strategic priorities and meeting our statutory duty to deliver best value during the year 2022/23. It provides elected members, officers and the public with a clear understanding of the performance achieved and case studies providing illustrative examples of 5 Page 15 of 98
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Exempt progress on our work towards a Perth and Kinross where everyone can live life well, free from poverty and inequalities. 4.2 In previous years, we have produced a separate online dashboard, PK Performs with further detailed information on indicators. This year, however, as we transition to new performance reporting and strategic planning arrangements, we are presenting detail on indicators within the main body of the APR. Detail on improvement actions will follow later in the year through a Corporate Delivery and Improvement Plan, which will be brought in a draft version to Council in October 2023. 4.3 Maintaining a robust and effective performance management framework that includes public reporting is critical to the success of the Council in delivering and improving outcomes for individuals and our communities. 5. SUMMARY INFORMATION 5.1 The Council’s APR for 2022/23 is a high-level summary of the impact that Council services collectively had in the period 1 April 2022 to 31 March 2023. It provides a summary of trends in data against each of the indicators, however, these should be considered in the context of the current operating environment, challenges and whether we control, influence or are informed by the data. 5.2 As the Corporate Plan was published part way through the financial year, in December 2022, and included new indicators, we did not include target information against which performance could be measured for this year. In future years, we will provide a summary of the number and percentage of Key Performance Indicators (KPIs) which have performed above and below target. 5.3 Within the APR we have reported our performance against the seven key priorities and associated actions. These are aligned to each of the priorities and actions identified within the Corporate Plan and provide more detail and data on KPIs, performance and improvement. 5.4 We have also prepared a shorter performance summary document which summarises the overall data trends of our key performance indicators within each priority area. This shorter version will help support our public performance reporting activity on our website and via social media. 5.5 Throughout the report, there are many examples of how services have continued to have a positive impact on outcomes for individuals, businesses and communities. These include: • Supporting over 900 tenants to access specialist money advice through a dedicated financial hardship project with Citizens Advice Bureau, helping to minimise the impact of the cost of living crisis and prevent some from losing their home • Organising support for over 16,500 people with warms spaces, food and warm home packs in response to the cost of living crisis • Increasing the number of households who have access to kerbside dry mixed and food waste recycling services. • Improving biodiversity through changes to our grass cutting regimes and provision of funding to community projects Page 16 of 98
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Exempt • Supporting a £1.5m project in central Perth, which brought approximately 900m2 of disused commercial space back into use, whilst directly creating 32 highly skilled jobs. • Co-ordinating delivery of the Volunteer Development Fund, which benefited 1,034 volunteers with either to access training and learning or resources relevant to their roles. • Improving attainment of literacy and numeracy skills for primary school pupils. • Reducing the poverty-related attainment gap at both SCQF level five and level six. • Receiving validation regarding our strategic leadership of adult support and protection, demonstrating how we are keeping vulnerable adults safe and protected. • Commissioning an externally hosted platform to better understand peoples’ experiences across health and social care on a more routine basis. • Investing over £1 million in active travel infrastructure to encourage residents and visitors to walk and cycle in Perth and Kinross. • Supporting over 300 community groups to increase their capacity. • Working in partnership with communities and others to develop an action plan for Coupar Angus which addresses priority issues including health and wellbeing, poverty, social isolation, and employability. 5.6 Despite all of these successes, we are not complacent and recognise the many challenges we faced within 2022/23, and those that lie ahead. The report recognises some of these challenges and the work that we are doing to make positive change. 5.7 In addition to reporting on performance against the actions and indicators set out within our Corporate Plan and in line with the new statutory performance information direction, we have created a supplementary report on performance aligned to the Best Value themes. This report is published on our website with a link included within the APR document. 5.8 Improvement and key delivery activity for 2024/25 will be published in our Corporate Delivery Improvement Plan, which will be brought to Council in October, alongside the Medium-Term Financial Plan. This new reporting arrangement will strengthen the alignment between Corporate Plan performance, improvement activity, budget and resource allocation and the involvement of communities in decision making and influencing Council priorities. Page 17 of 98
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Exempt Authors Name Designation Contact Details Charlene Guild Head of Innovation cguild@pkc.gov.uk Approved Name Designation Date Clare Mailer Executive Lead – Strategic Planning and Transformation 22 August 2023 Page 18 of 98
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Exempt ANNEX 1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND COMMUNICATION Strategic Implications Yes / None Community Plan / Single Outcome Agreement None Corporate Plan Yes Resource Implications Financial None Workforce None Asset Management (land, property, IST) None Assessments Equality Impact Assessment None Strategic Environmental Assessment None Sustainability (community, economic, environmental) None Legal and Governance None Risk None Consultation Internal Yes External None Communication Communications Plan None 1. Strategic Implications Community Plan / Corporate Plan 1.1 This report demonstrates the achievements and challenges associated with delivery of the Council Corporate Plan 2022-27. 2. Resource Implications Financial 2.1 There are no financial implications arising from this report. Workforce 2.2 There are no workforce implications arising from this report. Asset Management (land, property, IT) 2.3 There are no asset management implications arising from this report. Page 19 of 98
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Exempt 3. Assessments Equality Impact Assessment 3.1 Under the Equality Act 2010, the Council is required to eliminate discrimination, advance equality of opportunity, and foster good relations between equality groups. Carrying out Equality Impact Assessments for plans and policies allows the Council to demonstrate that it is meeting these duties. 3.2 This report has been considered under the Corporate Equalities Impact Assessment process (EqIA) with the following outcome: (i) Assessed as not relevant for the purposes of EqIA Strategic Environmental Assessment 3.3 The Environmental Assessment (Scotland) Act 2005 places a duty on the Council to identify and assess the environmental consequences of its proposals. no further action is required as it does not qualify as a PPS as defined by the Act and is therefore exempt. Sustainability 3.4 Under the provisions of the Local Government in Scotland Act 2003 the Council has to discharge its duties in a way which contributes to the achievement of sustainable development. Under the Climate Change (Scotland) Act 2009 the Council also has a duty relating to climate change and, in exercising its functions must act: • in the way best calculated to delivery of the Act’s emissions reduction targets; • in the way best calculated to deliver any statutory adaptation programmes; and • in a way that it considers most sustainable. 3.5 The information contained within this report has been considered under the Act. However, no action is required as the Act does not apply to the matters presented in this report. Legal and Governance 3.6 Not applicable. Risk 3.7 Not applicable. 4. Consultation Internal Page 20 of 98
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Exempt 4.1 The Executive Leadership Team, Service Senior Management Teams and the Performance, Planning and Risk Group were consulted during the preparation of this report. External 4.2 Not applicable. 5. Communication 5.1 Not applicable. 6. BACKGROUND PAPERS 6.1 None. 7. APPENDIX 7.1 Perth and Kinross Council Annual Performance Report 2022/23. 7.2 Annual Performance Report Executive Summary 2022/23. Page 21 of 98
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Exempt PERTH AND KINROSS COUNCIL Scrutiny and Performance Committee 13 September 2023 FOI PERFORMANCE REPORT 2022-23 Head of Legal and Governance Services (Report No. 23/246) 1. PURPOSE 1.1 This report describes the Council’s performance in relation to its obligations under the Freedom of Information (Scotland) Act 2002 (FOISA) and Environmental Information (Scotland) Regulations 2004 (EIR) for the year 2022-23. 1.2 The report also provides an overview of some of the Council’s other information-related activities. 2. RECOMMENDATIONS 2.1 It is recommended that the Committee: i. Considers the content of this report and provides constructive comment and feedback. ii. Notes that performance is improving and is back in line with pre- pandemic levels. iii. Notes that the number of requests for review remains a very small percentage of requests received, indicating good levels of customer satisfaction in terms of the quality of responses and the effectiveness of the process. 3. STRUCTURE OF REPORT 3.1 This report is structured over the following sections: • Section 4: Background/Main Issues • Section 5: Proposals • Section 6: Conclusion • Appendices 4. BACKGROUND / MAIN ISSUES Executive summary 4.1 The number of requests in 2022-23 increased by 15% from the preceding year. The period which experienced the biggest increase in numbers was Quarter 4. 6 Page 77 of 98
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Exempt 4.2 The Council’s target for responding to FOI requests within statutory timescales is 95%. In 2022-23, 93% of requests were responded to on time. This represents a 5% improvement in performance on what was achieved during 2021-22. 4.3 The number of requests for review represents 2% of the total number of requests received, which indicates good levels of customer satisfaction in terms of the quality the Council’s responses and the effectiveness of our process. Performance 4.4 During 2022-23, the Council received 1573 requests for information under FOISA. This is an increase of 15% on the number of requests received during 2021-22 and represents a return to pre-pandemic levels. 4.5 The largest increase was during Quarter 4, when 29% more requests were received than during the corresponding period in 2021-22. Figure 1 – Number of requests for information under FOISA/EIRs 4.6 Of the 1573 requests received: - • 22 were subsequently rejected when no clarification was received from the requestor; and • 28 were withdrawn by the applicant. 4.7 Of the 1573 requests received, 203 were processed under the EIRs. 4.8 Figure 2 below shows the number of FOISA/EIRs requests received in the year, broken down by month. 0 200 400 600 800 1000 1200 1400 1600 1800 No. of requests 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 Page 78 of 98
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Exempt Figure 2 – Number of requests April 2022 to March 2023 by month 4.9 Analysing the requests received based on the type of applicant shows the highest single group making requests are members of the general public. During 2022-23, 812 (or 48%) of the requests received were from members of the public; this represents a decrease of 29% on 2021-22. There has been a significant increase in requests received from Elected Representatives and Interest Groups. During 2022-23, 232 (or 14%) of the requests received were from Elected Representatives; this represents an increase of 77% on 2021-22, when 30 requests were received. During 2022-23, 113 (or 7%) of the requests were received from Interest Groups (groups seeking to influence public policy or promote particular causes); this represents an increase of 30% from 2021-22, when 34 requests were received. A breakdown is illustrated at Figure 3 below: Figure 3- Summary of type of applicant. 4.10 In the course of the year, the Council may receive several requests from the same requestor. During the year 2022-23, requests were made by 1014 requestors. The number of requests is broken down as follows: - • 827 requestors each made a single request for information; • 177 requestors made 2 to 10 requests for information; and 0 50 100 150 200 Apr May Jun July Aug Sep Oct Nov Dec Jan Feb Mar No of Requests No of Requests 0 200 400 600 800 1000 1200 2016-17 2017-18 2018-19 2019-20 2020-21 2021-22 2022-23 Individuals Media Legal Business Elected Reps Interest Groups Other Page 79 of 98
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Exempt • 10 requestors made more than 10 requests for information, totalling 242 requests. One requestor made 67 requests for information. 4.11 There was a 198% increase in the number of requests received from the media during 2022-23 (185 requests) when compared to 2021-22. During 2021-22, an unusually low number of requests from the media were received (62); this may have been because of a different news agenda during the Covid 19 pandemic. Performance Monitoring 4.12 The Council’s target for responding to requests within statutory timescales is 95%. During 2022-23, 93% of requests were completed within timescales. 4.13 While this is lower than the Council’s target, there was a 5% improvement in performance in comparison to 2021-22. Workload pressures across the organisation have had an impact on the time taken to collate information to provide to the Information Rights team for processing and release. 4.14 Of the 1573 valid requests for information received by the Council during 2022-23: - • 688 (44%) requests were satisfied in full (all the information requested was held by the Council and could be released without redaction of e.g., personal information) • 486 (31%) requests were satisfied in part • 399 (25%) requests resulted in no information being issued. 4.15 Where information was not provided to requestors, 15 requests were refused completely or in part on the grounds of excessive cost. 4.16 In almost all other cases where no information was issued, this was because either the Council did not hold the information, it was publicly available, or it consisted of personal information which cannot be released under Freedom of Information legislation. 4.17 A new case management system for recording, processing and reporting on information requests more efficiently will come into use in August 2023. Reviews and Appeals 4.18 The Council received 31 requests to review its decision (complaints about the original response to FOI requests received during 2022-23), which represents 2% of the total requests received. A breakdown of the relevant review data is contained in Figure 4: - Page 80 of 98
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Exempt Figure 1 – Summary of request for reviews 4.19 All requests for reviews were responded to within the statutory 20 working days deadline. 4.20 During 2022-23, there were two appeals to the Scottish Information Commissioner following reviews carried out during 2021-22. In both cases, the applicants withdrew their appeals before a decision was issued by the Commissioner. There is currently one appeal under investigation by the Scottish Information Commissioner. 5. CONCLUSION 5.1 The number of requests in 2022-23 increased by 15% from the preceding year. 5.2 The Council’s performance in responding to information requests within statutory timescales improved by 5% during 2022-23. 5.3 The number of requests for review remains a small percentage of the total number received which would indicate good levels of customer satisfaction in terms of the quality the Council’s responses and the effectiveness of our process. 5.4 The number of appeals to the Office of the Scottish Information Commissioner remains extremely low. Author(s) Name Designation Contact Details Jillian Walker Information Rights Manager/Data Protection Officer DPO@pkc.gov.uk Approved Name Designation Date Lisa Simpson Head of Legal & Governance Services 4 August 2023 Karen Donaldson Chief Operating Officer 9 August 2023 0 5 10 15 20 25 30 35 Review requests Total no. processed No. processed within 20 working days Original decision upheld Decision overturned Vexatious or withdrawn Page 81 of 98
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Exempt ANNEX 1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND COMMUNICATION Strategic Implications Yes / None Community Plan / Single Outcome Agreement n/a Corporate Plan n/a Resource Implications n/a Financial n/a Workforce n/a Asset Management (land, property, IST) n/a Assessments n/a Equality Impact Assessment n/a Strategic Environmental Assessment n/a Sustainability (community, economic, environmental) n/a Legal and Governance n/a Risk n/a Consultation n/a Internal n/a External n/a Communication n/a Communications Plan n/a 1. Strategic Implications Not applicable. 2. Resource Implications Not applicable. 3. Assessments • Equality Impact Assessment – not applicable • Strategic Environmental Assessment – not applicable • Sustainability – not applicable • Legal and Governance – not applicable • Risk – not applicable 4. Consultation Not applicable. 5. Communication Not applicable. Page 83 of 98
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Exempt 2. BACKGROUND PAPERS None. 3. APPENDICES None. Page 84 of 98
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Exempt PERTH AND KINROSS COUNCIL Scrutiny and Performance Committee 13 September 2023 DATA PROTECTION COMPLIANCE 2022-23 Report by Data Protection Officer (DPO) (Report No. 23/247) 1. PURPOSE 1.1 This report is the professional assessment of the Council’s compliance with the UK General Data Protection Regulation (GDPR) by the Data Protection Officer (as is required to be provided by her in accordance with the legislation). This report relates to the year 2022-23. 2. RECOMMENDATIONS 2.1 It is recommended that the Committee: (i) Notes the DPO’s assessment of the Council’s compliance with the requirements of data protection legislation. (ii) Considers the Council’s performance in terms of compliance with the GDPR and provides constructive scrutiny and comment. (iii) Notes that the DPO is confident that a reasonable degree of compliance with data protection legislation has been achieved during 2022-23 and that progress towards increased compliance across all Services will continue during 2023-24 3. STRUCTURE OF REPORT 3.1 This report is structured over the following sections: • Section 4: Background • Section 5: Data Breaches • Section 6: Data Subject requests • Section 7: Policy and Process • Section 8: Training • Section 9: Improvement Actions • Section 10: Conclusion 4. BACKGROUND 4.1 The UK General Data Protection Regulation (“GDPR”) requires the Council, as a public authority, to appoint a Data Protection Officer (“DPO”) and defines tasks that the person must undertake. These tasks include monitoring and 7 Page 85 of 98
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Exempt reporting on compliance with the GDPR. The Council’s Data Protection Policy sets out that the DPO will present a report on the Council’s data protection compliance to the Scrutiny and Performance Committee annually or more frequently, if considered necessary. It is the role of the Scrutiny and Performance Committee to consider the DPO’s report in relation to the Council’s compliance and to provide appropriate constructive challenge and comment. Role of DPO 4.2 The role of the DPO is defined in the GDPR; the legislation places particular restrictions on both the DPO and the Council in terms of roles and responsibilities. The DPO, like the other Statutory Officers within the Council, has an independent and autonomous role and the Council cannot instruct the DPO how to undertake the role. It should be noted that legal responsibility for compliance with data protection law lies with the Council as a public body and not the DPO as an individual. The DPO does have a role in providing advice and guidance to support the Council in complying with the legislation and to monitor and report on its performance. The Committee can be assured that all formal advice provided by the DPO, to date, to support the organisation and ensure compliance, has been accepted. 4.3 The DPO and the Information Rights Team sit within the Audit and Governance Team, with the DPO maintaining a separate and distinct reporting line to the Head of Legal and Governance Services in her capacity as Senior Information Risk Officer. Resources of DPO 4.4 The legislation also provides that adequate resources should be made available to the DPO to enable them to fulfil their role. The Data Protection Officer function does not have a dedicated team but is supported by the Information Rights (formerly the Information Governance team) and Information Security teams (referred to as the DPO’s team for the purposes of this report). In terms of skills and expertise, as well as the DPO, there are 2 officers (1.7 FTE) within the Information Rights team who have specialised data protection knowledge. At present, almost all staff time is required to deal with increasing volumes of complex responsive work. 5. PERFORMANCE: DATA BREACHES 5.1 A data breach is defined as an incident involving “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data”. The term ‘security’ refers to both technical measures and organisational measures such as policy, procedures and practice. 5.2 The Council is required to maintain a register of data breaches and, where appropriate, report them to the Information Commissioner’s office. Page 86 of 98
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Exempt 5.3 Between 1 April 2022 and 31 March 2023, the Council recorded a total of 95 data breaches (compared to 134 during the previous year). This 29% reduction in the number of breaches may be attributable to increasing awareness of what constitutes a data breach, advice on improving processes previously provided by the Information Rights team and greater familiarity with technology and processes adopted rapidly during the pandemic. However, it is recognised that continued training on recognising and reporting data breaches would provide assurance that all breaches were reported appropriately. Any data breach is a matter which the DPO takes seriously, but in terms of numbers, this figure needs to be considered in the context of the many millions of interactions and transactions involving the processing of personal information entailed in the delivery of all Council services in the course of a year. The split of data breaches by Service is illustrated below: - 5.4 The nature of the data breaches was as follows: - 8 23 55 9 0 10 20 30 40 50 60 HSCP Corporate & Democratic Education & Childrens Services Communities Number of Data Breaches 70 1 23 1 0 10 20 30 40 50 60 70 80 Unauthorised disclosure Unauthorised access Email error Data Loss Nature of breaches Page 87 of 98
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Exempt 5.5 In relation to the data breaches which have been recorded, the DPO confirms that: - • almost all recorded breaches were reported promptly to the DPO and any remedial action which was requested was taken quickly; • where breaches have been identified, the relevant service area has been keen to engage with the DPO to amend and improve practice; • of the recorded breaches, particularly those categorised as email error or unauthorised disclosure breaches, almost all appear to be attributable to human error as a consequence of resource pressures within the relevant service areas as opposed to any systemic failure of process or policy; and • of the 95 breaches, the DPO determined that 6 required to be reported to the Commissioner’s Office (ICO) following a risk-based assessment of potential impact on the data subject based on the nature/ circumstances of the information disclosed. 5.6 Of the 6 breaches reported to the ICO: - • Five of these breaches were due to the unauthorised disclosure of personal information and one to the loss of data. • In relation to all of the reported breaches, the ICO was satisfied that the actions taken by the Council in response to the breaches were appropriate and did not require any further action. 5.7 The DPO provides support and advice to services and teams when a data breach has occurred and, where necessary, provides additional staff training and written guidance. 5.8 The DPO considers that there is a generally good and increasing understanding across the Council in relation to what constitutes a data breach. Breaches will continue to be monitored and advice and training provided as appropriate. 6. PERFORMANCE: DATA SUBJECT REQUESTS 6.1 The GDPR gives data subjects a number of specific rights, such as accessing and receiving a copy of information held about them, and having inaccurate personal data rectified. Requests to exercise these rights must be responded to within 1 month (interpreted by the Council as 28 calendar days), unless the information requested is particularly complex in nature or the request is from an individual who has made multiple requests; in these cases, an additional two months to respond is permitted by the legislation. The DPO has responsibility for dealing with requests received by the Council. 6.2 There was a 27% increase in the number of subject access requests received during 2022-23, compared to 2021-22. This increase is partly attributable to individuals seeking confirmation of their care experience, in order to apply to Scotland’s Redress Scheme for survivors of historical child abuse in care. Many of the records processed in relation to this scheme contain a very large Page 88 of 98
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Exempt volume of information, some of which will contain sensitive personal information relating to other individuals which may require to be redacted. 6.3 Between 1 April 2022 and 31 March 2023, the Council received 211 requests for access to personal information, of which: - • 154 have been completed. • 57 are on hold pending further information from the requester (this is sometimes never provided) or a decision on whether they wish to proceed with making a request. 6.4 Of the 154 requests that were processed: - • 129 were completed within 28 days (84%). • 25 were responded to outwith the 28-day timescale (16%). 6.5 Eighteen (72%) of those requests processed outwith the 28-day timescale were complex requests, where the legislation permits an extension period of up to two months. In many of these cases, information was released in batches i.e., individuals received at least of part of their information within the first 28 days. 6.6 Over and above the 211 data subject access requests referred to above, the Council received 10 other data subject requests during 2022-23: - • 3 requests for erasure (individuals have the right to request their personal data is deleted); • 6 requests for rectification (individuals can request that inaccurate personal data is corrected); and • 1 request regarding processing (individuals can request that the processing of their information is restricted). 6.7 In addition, the Council also received 38 information related complaints, either directly from the data subjects or via the ICO, about the way personal data had been handled. All these complaints have been dealt with. 6.8 The Information Rights team also processed 43 requests for information made during 2022-23, under a provision in data protection legislation which permits authorities, such as Police and HMRC, to request personal information to assist with criminal investigations and the assessment and collection of taxes. 6.9 During 2022-23, the process through which information held in relation to historical and current childcare files was streamlined. Rather than asking officers from Education and Children’s Services to carry out searches and extract information, officers from the Information Rights team now access systems directly to identify and extract information held. 6.10 Applicants for compensation from Scotland’s Redress Scheme can ask the Council to verify that they have not previously received compensation related to their experience in care. The Information Rights team now carries out these Page 89 of 98
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Exempt verification checks and liaises directly with the Scheme, rather than this work being carried out by Education and Children’s Services. 6.11 The Council is sometimes unable to provide information requested by survivors of historical child abuse in care, usually because the person in question was in an institution not run by local government. Recognising the distress that this may cause applicants, work by the Information Rights team to identify the location of records and to work with other local authorities and educational establishments to ensure as comprehensive a response as possible is provided, is ongoing. 6.12 Where information held about requestors may cause them distress, the Information Rights team now provides advance warning of this before issuing their response. Individuals are regularly signposted to organisations that can provide them with support going through their records. 6.13 A new case management system for recording, processing and reporting on information requests more efficiently will come into use in August 2023. 6.14 The DPO is satisfied that data subject requests are being handled appropriately within the resources available. 7. SURVEILLANCE & INTERCEPTION OF COMMUNICATIONS 7.1 The Council has powers under the Regulation of Investigatory Powers (Scotland) Act to undertake directed surveillance and to utilise covert human intelligence sources. The Council also has powers under the Regulation of Investigatory Powers Act to obtain information (‘intercept’) about electronic communications. 7.2 Council officers have a duty to report on the use of these powers to Elected Members. 7.3 During 2022/23, no directed surveillance was authorised, no covert human intelligence sources were used, and no electronic communications information was obtained. 7.4 The Council’s policy statement on the use of directed surveillance and the intercept of communications is attached as Appendix 1. 8. TRAINING 8.1 Throughout the year, the importance of data protection has been signposted to all staff through use of the Council’s intranet and Managers’ briefings, as well as reminders about data protection issues in staff communications, at the DPO’s request. 8.2 The DPO has also delivered targeted training sessions to individual teams and groups of staff, on request throughout the year. Page 90 of 98
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Exempt 8.3 The DPO and her team provided training to elected members following the election of the new Council in May 2022. Support, awareness- raising and advice is provided to councillors on an ongoing basis, as required. 8.4 It is acknowledged that increasing workload of the small team has limited the ability to provide more general training throughout the year. 8.5 New online data protection training will be made available to all Council staff during August 2023. 8.6 The DPO considers there to be a reasonable level of general awareness across the Council and notes that staff appear to be willing to seek advice and support from the DPO. 9. DATA PROTECTION POLICY AND PROCESS 9.1 The DPO is satisfied that the Council has a Data Protection Policy which complies with the separate requirements of the UK GDPR and the Data Protection Act 2018. 9.2 It is a statutory requirement that the Council be able to provide evidence of its compliance with the legislation at all times. Compliance is therefore documented and evidenced by the Council’s use of: - • Data Protection Impact Assessments (DPIAs) • Detail of Data Processing Agreements • Privacy Notices • Data Sharing Agreements (DSAs) 9.3 It is the responsibility of the Council to carry out DPIAs and ensure Data Processing Agreements and Privacy Notices are in place. The role of the DPO is to assist and advise in their creation and to maintain registers of the documentation. 9.4 The DPO is satisfied that there is some form of privacy notice in place in relation to all processing of personal information carried out by the Council. Processing may be covered by the General Privacy Notice which appears on the Council website or by more specific short or detailed privacy notices. The DPO continues to monitor, review and provide advice to services as required. Privacy notices are required where we collect personal data. The Council has a general privacy notice in place and short privacy notices are generally in place as required. Work is ongoing with Services to ensure that corresponding detailed privacy notices are also in place. 9.5 Where personal information requires to be shared with other parties (e.g., Police, Health etc) best practice requires that Data Sharing Agreements should be put in place. These are specialised documents which tend to be lengthy and time-consuming pieces of work, often needing extensive consultation with the other organisations involved. The DPO is satisfied that Page 91 of 98
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Exempt Data Sharing Agreements are in place where required, and that the Council is adopting best practice wherever possible. 9.6 The UK government has announced its intention to make changes to data protection legislation. The draft Data Protection and Digital Information Bill, which was introduced in June 2022, amended rather than repealed existing legislation. After a period of consideration, this Bill was withdrawn and the Data Protection and Digital Information (No. 2) Bill was introduced to Parliament in March 2023. This is being now being considered as part of the wider legislative process. The extent of the proposed changes is expected to be relatively limited; however, there will be a requirement to review our policies and processes once the new legislation comes into force. 10. IMPROVEMENT ACTIONS 10.1 Work to further streamline processes in relation to collating responses to subject access requests will continue during 2023-24. 10.2 Training on recognising and reporting data breaches will be developed and delivered during 2023-24 to ensure as far as possible that all incidents are reported to the DPO. 11. CONCLUSION 11.1 Given the breadth of all local authorities’ activities and the millions of transactions involving personal data that are processed each year, no local authority can state categorically that it is fully compliant with data protection legislation. It is the opinion of the DPO, however, that the Council continues to achieve a reasonable and acceptable level of compliance. 11.2 The DPO is satisfied that the principles of GDPR compliance are understood and embedded as normal practice across the Council. When procedural failings involving data protection occur, these can almost always be attributed to human error as opposed to a systemic failure in terms of policy or process. 11.3 Whilst the Council would wish to avoid any data breach, given the volume and range of personal information which it processes, the number of reported breaches remains very low, with only a small percentage of these meeting the threshold requiring them to be reported to the Information Commissioner’s Office. Author(s) Name Designation Contact Details Jillian Walker Data Protection Officer DPO@pkc.gov.uk Page 92 of 98
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Exempt Approved Name Designation Date Lisa Simpson Head of Legal & Governance / Senior Information Risk Officer 8 August 2023 Karen Donaldson Chief Operating Officer 9 August 2023 Page 93 of 98
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Exempt ANNEX 1. IMPLICATIONS, ASSESSMENTS, CONSULTATION AND COMMUNICATION Strategic Implications Yes / None Community Plan / Single Outcome Agreement n/a Corporate Plan n/a Resource Implications n/a Financial n/a Workforce n/a Asset Management (land, property, IST) n/a Assessments n/a Equality Impact Assessment n/a Strategic Environmental Assessment n/a Sustainability (community, economic, environmental) n/a Legal and Governance n/a Risk n/a Consultation n/a Internal n/a External n/a Communication n/a Communications Plan n/a 1. Strategic Implications Not applicable. 2. Resource Implications Not applicable. 3. Assessments • Equality Impact Assessment – not applicable • Strategic Environmental Assessment – not applicable • Sustainability – not applicable • Legal and Governance – not applicable • Risk – not applicable 4. Consultation Not applicable. 5. Communication Not applicable. Page 94 of 98
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Exempt 2. BACKGROUND PAPERS None. 3. APPENDICES The Regulation of Investigatory Powers (Scotland) Act 2000 Policy Statement. Page 95 of 98
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