The Information Commissioners Office (ICO) has published a public consultation on changes to the notification process for organisations processing personal data. Currently data controllers are required to submit and annually renew their notification with the ICO, describing the purposes of their personal data processing according to standard definitions.
In an attempt to simplify the notification process, the ICO is consulting the public and data controllers on the following proposed changes:
- introducing an online and telephone service for the payment and renewal of notification fees;
- identifying in the notification form the contact details the data controller would like the public to use when requesting information or submitting other data protection enquiries; and
- introducing a narrative-based approach in relation to the purposes of processing where a data controller will be able to describe in their own words how they process personal data.
Although certain standard templates will still be available, the move towards a narrative-based approach is considered by the ICO as the best way to make the “public register more helpful and accessible.”
There are several concerns with a narrative approach, such as it being more onerous on data controllers and it leading to a lack of consistency between data controllers thus resulting in confusion for individuals. The consultation closes 30 November.