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Reply from Quarriers regarding Children's files.

27 November, 2006

Dear Mr Whelan

Thank you for your email, dated 7 November 2006.†Please find answers to each of the questions outlined in your email.

1.  How are the records being processed?

The contents of one file at a time are taken from their folder in Filesafe's scanning room and each sheet of paper is passed through a scanner and returned to its folder. Another operator then creates an index entry linking that record to the named individual whose record it is. This index allows the record to be accessed within the database.

2.  For what purposes are the records being processed?

To preserve them in more than one format, making the information less susceptible to loss through for example, fire or flood.
To improve speed of access to authorised aftercare/records staff and improve the efficiency of the service delivered.

3.  What is the content and detail of the records being processed?

Whatever is in the file is in the digital copy. The Filesafe employee scans every document that is in the file.

4.  How long does Filesafe intend to keep these records?

Filesafe will store the original records for as long as Quarriers contracts with the company to do so.

5.  What measures have Filesafe taken to ensure that the records are kept secure?

The methods are as previously notified to you. The records are boxed and stored in specialised storage facilities where confidential documents from numerous other companies are also stored, in identical boxes. There are several thousand identical boxes. The location of any box requires the searcher to have access to the company's storage location database and the knowledge to use it. This is limited to specific employees. The facility is protected by laser security alarms, smoke detectors, security screens on the windows to the offices (there are no windows in the storage facilities).

6.  When will the transfer and processing of all Quarriers children's records be completed?

By the summer of 2007.

7.  What procedures have Filesafe implemented to record all data access requests and viewings?

The only people who can receive a file are authorised by Quarriers Chief Executive. Filesafe would extract the requested file from the box and personally bring it to Quarriers, noting the movement on their database. There should not be many instances where access to the original record is necessary when the whole record can be accessed from the database disc.

8.  What automated or manual operations on the records does Filesafe expect, and with what frequency?

Filesafe will do nothing with the records once they have been scanned except maintain them in their storage facility. Unless a request is made by the named Quarriers authorised employees, Filesafe need never look at or do anything with the records. Its task is to maintain the security of the building housing the records, protecting it from unwarranted intrusion and weather conditions.

9.  Where will the electronic records be physically located?

The electronic record will be contained on two or three DVDs which, when not in use, will be kept in a locked facility accessible to the Chief Executive and the two Aftercare employees. The records already scanned are already so stored.
Filesafe will maintain an electronic version of the records as a back up in case of need and to enable additions to be made.

10.  Where will the original manual records be physically located?

See answer to 5.

11.  What measures have Filesafe taken to ensure that a data subject's rights are safeguarded?

Filesafe's responsibility is to keep the boxed records securely and to return a file to Quarriers when requested to do so by staff authorised by the Chief Executive of Quarriers. It is not Filesafe's responsibility to ensure the safeguarding of a data subjectís rights. It is Quarriers responsibility to ensure that the company who is acting on its behalf has in place measures that ensure the physical safety of the records and the removal of a record only under identified conditions, i.e. on the personal request of the Chief Executive or staff nominated by him and identified to Filesafe.

12.  What measures have Filesafe taken to ensure that the records are accurate?

Filesafe has a responsibility to ensure that every document in the record given to it, is scanned and added to the digitised record. It has no responsibility for nor would it have the capability to assess the accuracy of a record. As a company it is not concerned about the content of any record, it is concerned with the process by which a written record gains a digital version of itself. It manages many sorts of data for a variety of clients; it takes no interest in the meaning of any of the content of any of the documents it handles. It sees every item as simply information on a sheet of paper that the client wishes to be able to access via a disc/computer. In some cases clients do not need or want the original documents to be retained, in others they do, so they have developed secure storage facilities for this.

13.  What are Filesafe's procedures to permit a data subject to access and verify the accuracy of their records as allowed for in law?

As stated in 11. Filesafe is not involved in that process. If a subject wishes access to the original, in addition to the computer accessible version of his/her records, the request is made to Quarriers. Filesafe cannot respond to requests from members of the public/former boys or girls or anyone else. It will deal only with authorised staff from Quarriers.

14.  What decisions does Filesafe expect to be made on the basis of these electronic records?

There are no decisions to be made on the basis of these electronic records, just as there are no decisions to be made on the basis of the written records. Records simply exist and those who have a right to access them can do so by making their request to Quarriers (with verification of their identity where the request relates to a living former boy or girl).

15.  Under what circumstances and on what date was the decision taken to transfer the electronic processing of the records to Filesafe?

The term 'transfer' indicates something moving from one place to another. In the case of the records, the information is being made accessible through an extra medium as well as the original one. It had been under consideration for several years but could not be undertaken until there was funding for it. As already stated at Q2 it will improve access and preservation.

16.  What Filesafe personnel will have access to these records?

Quarriers database is one of many held for the purposes of support and 'insurance' by Filesafe. The data in other databases is sensitive and confidential (commercial interests for instance) as is the original material stored. Employees of the organisation are committed to ensuring the confidentiality of all the thousands of records they hold and can be held accountable in the very unlikely event of any breach of confidentiality.

17.  What measures will be in place to ensure that only designated Filesafe personnel have access?

Only Filesafe employees are allowed in the building which is accessible only through secure entry. Visitors are of course allowed where appointments have been made and the visitor is under the supervision of a Filesafe employee at all times.

18.  How will this be managed and logged to ensure security and audited?

Only authorised Filesafe staff are allowed entry. No-one else is allowed on site without prior arrangements and no-one is given access to the records without written authorisation from Quarriers. The very small numbers of Filesafe staff who have access all have full confidentiality agreements in place. All actions are logged by the Index Supervisor and audited by the Quality Manager at Filesafe.

19.  How will they log, manage and keep a record of any other individuals from Quarriers Charity given permission to access these files or for that matter anyone who requests such access?

No one other than the Chief Executive and specified Aftercare/Records staff known to Filesafe is authorised to receive records from Filesafe. Authorised requests will be noted on the database in order that the company can track the record going out and being returned. If Filesafe were to be contacted by others they would be informed of the route through which they had to go if they wanted access to a record ie. contact Quarriers Head Office. The company would inform the Chief Executive if requests were being made repeatedly by non-authorised people. If relevant people ie. the subject of a record or a descendent of a deceased former boy or girl, require information from the records that information can be obtained by authorised staff from the digital version of the record held by Quarriers.

20.  Were the Scottish Executive Officials involved in the process to nominate Filesafe or in any decision/process concerning the management of these Confidential Children's Files?

Filesafe was not nominated to do the work. When the task was made known, the company submitted a tender which was considered and accepted. This area of work is not the concern of the Scottish Executive.

Yours sincerely

Phil Robinson

Chief Executive

Cc:  M Cawley, Service Director
       D Williams, Service Director
       H Walker, Director of Finance & Corporate Services
       P Barr, Aftercare Worker.

 
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