Subject Access Request (SAR) and Freedom of Information (FOI) Lead

Job overview

The post holder will be the Trust lead for meeting the organisation’s statutory obligations under the Data Protection Act 2018 and Freedom of Information Act 2000 in relation to responding to Subject Access and Freedom of Information Requests.

They will be the Trust lead and Subject Matter Expert for FOI, ensuring all requests are responded to, and advising the Trust on the use of exemptions where appropriate The postholder will ensure that the Trust has robust, up to date and fit for purpose policies and procedures to respond to SAR and FOI requests. They will oversee the work of the IG team in responding to Subject Access Requests and Freedom of Information requests in line with statutory timescales and ensure requests are appropriately logged and tracked.

The post holder will have direct contact with members of the public as well as staff and service users, and must be a confident communicator with a keen focus on delivering excellent customer service.  The role will support compliance with the following legislations •UK General Data Protection Regulation (GDPR) •Data Protection Act 2018 •Freedom of Information Act 2000 •Access to Health Records Act 1990 •Environmental Information Regulations 2004 (EIR) •Re – use of Public Sector Information Regulations 2015 •NHS Act 2006

Main duties of the job

• Take lead responsibility for the Trust's Individual Rights including Subject Access Requests (SARs) and Freedom of lnformation (FOIs) functions: ensure all requests are logged, tracked, responded to within statutory timescales and escalated appropriately.
• Provide specialist guidance and decision-making on complex or contentious requests, including application of exemptions, redactions, internal reviews, and liaison with other services. Manage the escalation process to ICO (or other regulators) when required - implement lessons learned and ensure root-cause analysis of breaches or late responses.
• Maintain and monitor the Trust's information risk register (in respect of IG, Individual Rights and FOI) and escalate significant risks.
• Support the collation and management of FOl publication scheme and ensure the website is up to date.
• Provide oversight or line-management (or deputise for) the IG team; ensure service level agreements, staffing, quality assurance of responses and training are in place.
• Ensure that the Trust has a compliant FOI Publication scheme which is up to date and includes all categories of information as required under the ICO guidance document.
• Support the IG Compliance Manager and Data Protection Officer.
• Develop & monitor KPIs and dashboards on Individual Rights and FOl performance, themes and trends; report to Information Governance Steering Group / Audit & Risk Committee.

Detailed job description and main responsibilities

• Responsible for the quality assurance checking of FOI and Individual Rights responses before they are released.
• Support the investigation of complaints relating to Individual Rights and FOIs
• Lead the collation of responses to Freedom of Information requests (FOI) working with colleagues across the Trust.
• Manage the Records Management Policy, including naming conventions, filing structures and file plans.
• Support the management of archiving and appropriate retention and destruction of official records in line with the Trust Policy.
• Support staff and stakeholders in the provision of appropriate filing structures, access control and management of electronic information.
• Developing and supporting a culture of high-quality information governance management practice including providing advice and guidance on the operation of corporate and clinical policies and data protection obligations where appropriate
• Implementing and supporting systems and practices which facilitate compliance with all legal, statutory and good practice requirements.
• Support with the implementation of the overarching Information Governance strategy to meet statutory and legal requirements.
• Take responsibility for the requirement of the Data Security and Protection Toolkit within your remit, ensuring that there is an auditable evidence base and to deliver satisfactory standard across all requirements.
• Liaise with the risk management function of the Trust to ensure the mitigation of risk and including managing the information risk register.
• Develop the information governance culture, working across stakeholders to communicate information governance standards and constantly seek to raise awareness.
• Be an expert in the requirements of UKGDPR, Individual Rights, EIR, and RPSI to facilitate best practice and ensure that this is communicated clearly and acted upon effectively.
• Work actively with Staff and stakeholders to ensure that the information governance processes meet best practice.

This is not an exhaustive list, Please see the attached Job Description and Person Specification for more information on the role requirements and duties.