NHS West Sussex Clinical Commissioning Group – Complaint Upheld (United Kingdom, 2020)

Complaint Upheld
Information Commissioner's Office28 August 2020United Kingdom
final
Complaint Upheld

General GDPR enforcement action

This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.

The UK's Information Commissioner's Office decided that NHS West Sussex Clinical Commissioning Group should have shared a job description that was requested. This decision matters because it emphasizes the need for transparency in public roles, even when personal data is involved.

What happened

NHS West Sussex Clinical Commissioning Group withheld a job description, claiming it was personal data, but the ICO ruled it should be disclosed.

Who was affected

The requester seeking information about the job description of a role involved in commissioning healthcare for patients with brain injuries.

What the authority found

The ICO decided that the job description should be disclosed as it serves a legitimate public interest and does not breach data protection principles.

Why this matters

This ruling underscores the balance between transparency and privacy, especially in public sector roles. Organizations should carefully assess the public interest in disclosing information that may also be personal data.

GDPR Articles Cited

Art. 5(1)(a) GDPR
Art. 6(1)(a) GDPR
Art. 6(1)(f) GDPR

National Law Articles

40(2) of the FOIA
40(3A)(3B) of the FOIA
Full Legal Summary
Detailed

The complainant has requested information to NHS West Sussex Clinical Commissioning Group (the CCG) relating to the job description of the officers commissioning of continuing health care for patients with Acquired Brain Injury, qualifications that are required fot the role and the standard contract used when commissioning the care. The CCG has withheld the job description under section 40 on the basis that it is the personal data of the post holder. There were several correspondence exchanges between two parties, in which the CCG did explain that there was only one person holding that post and the disclosure of the requested information would contravene the DP principles. The Commissioner had to decide if the CCG is entitled to withhold the job description under section 40. The Commissioner had to determined whether the requested information constitutes personal data, and if it is, it must establish whether disclosure of that data would breach any of the DP principles. The Commissioner’s decision is that the CCG is not entitled to withhold the job description under section 40. After having established that the requested information is personal data, (as there is only one person holding that post and the name of the individual is known) the Commissioner determined if the disclosure of the data would contravene the DP principles. As always, it considers the following three-part test (Article 6 GDPR) - i) Legitimate interest ii) Necessity and iii) Balancing tests. The Commissioner has established that there is a legitimate interest in the public understanding the role the CCG plays in providing services to vulnerable members of our society and examining its performance. As for necessity test, the Commissioner considers that there is a greater need to understand who is responsible for the individual elements of the process through which the care was organized and delivered. The provision of the job description would certainly assist the complainant in fo

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for NHS West Sussex Clinical Commissioning Group in UK

This is the only recorded action for this entity in this jurisdiction.

Details

Decision Date

28 August 2020

Authority

Information Commissioner's Office

GDPRhub ID

gdprhub-2706

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. NHS West Sussex Clinical Commissioning Group - United Kingdom (2020). Retrieved from cookiefines.eu

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