Sample policy on the secure handling, use, storage and retention of disclosure information
Introduction
[Organisation Name] will request Disclosure information as part of its selection procedure for certain posts within the organisation. We understand that the information received from Disclosure Scotland may be of an extremely sensitive nature and that we have a responsibility to ensure that it is only available to authorised persons, is stored securely and is disposed of in an appropriate manner.
[Organisation Name] complies fully with the Code of Practice, issued by Scottish Ministers, regarding the correct handling, holding and destroying Disclosure information provided by Disclosure Scotland under Part V of the Police Act 1997, for the purpose of assessing applicants’ suitability for positions of trust. It also complies fully with the Data Protection Act 1998 and other relevant legislation pertaining to the safe handling, use, storage, retention and disposal of Disclosure information and has a written policy on these matters. This policy is available to anyone who wishes to see it on request.
Usage
1. We use Disclosure information only for the purpose for which it has been provided. The information provided by an individual for a position within [Organisation Name] is not used or disclosed in a manner incompatible with the purpose. We process personal data only with the express consent of the individual. We notify the individual of any non-obvious use of the data, including further disclosure to a third party, identifying the Data Controller, the purpose for the processing, and any further relevant information.
Handling
2. [Organisation Name] recognises that, under section 124 of the Police Act 1997, it is a criminal offence to disclose Disclosure information to any unauthorised person. We, therefore, only pass Disclosure information to those who are authorised to see it in the course of their duties. [Organisation Name] will not disclose information provided under section 115(8) of the Act, namely information which is not included in the Disclosure, to the applicant.
Access and Storage
3. We do not keep Disclosure information on an individual’s personnel
file. It is kept securely, in lockable, non-portable storage containers.
Access to storage units is strictly controlled to authorised and named
individuals, who are entitled to see such information in the course
of their duties.
Retention
4. We do not keep Disclosures or Disclosure information for any longer than is required after a recruitment (or any other relevant) decision has been taken. In general, this is no longer than six months. This is to allow for the resolution of any disputes or complaints. Disclosure information will only be retained for longer than this period in exceptional circumstances, and in consultation with Disclosure Scotland. The same conditions relating to secure storage and access will apply during any such period.
Disposal
5. Once the retention period has elapsed, we will ensure that Disclosure
information is immediately destroyed in a secure manner. [Organisation
Name] will not keep Disclosure information which is awaiting destruction
in any insecure receptacle (e.g. a waste bin or confidential waste
sack). We will not retain any image or photocopy or any other form
of the Disclosure information. We will, however keep a record of:-
. the date of issue of the Disclosure
. the name of the subject
. the type of Disclosure
. the position for which the Disclosure was requested
. the unique reference number of the Disclosure
. details of the recruitment decision taken.
See also:
Central Registered Body in Scotland (CRBS)
[Updated March 2003]
