60
IPCO Annual Report 2017
8.46
In 2017, 39 authorities received 104 recommendations (7 Red, 68 Amber and 29 Green).
The 104 recommendations resulted from 61 inspections, an average of 1.7 recommendations
per public authority.
8.47
The recommendations can be placed in broad categories, although the seriousness of each
individual recommendation within a category may vary. Some recommendations address
more than one issue and may therefore have been included in more than one category:
• Applicants or DPs failed adequately to address the question of necessity (21);
• Applicants or DPs failed adequately to address the question of proportionality (29);
• Applicants or DPs failed to address the likelihood of collateral intrusion (29);
• Unreliable or inaccurate recording of errors (8);
• Erroneously acquired data was not destroyed (1);
• Insufficient consideration of sensitive professions (19);
• Improvements were required to the records for urgent oral applications (12);
• DPs’ reasons were not sufficiently tailored to the application (‘boiler plate’ reasons) (4);
• DPs did not review applications promptly or their reasons failed to address the
requirements of the code of practice (5);
• DPs failed to justify the grading of priority applications (4);
• The independence of DPs was called into question (10). As a consequence of recurring
matters relating to a lack of DP independence, the Commissioner asked two Chief
Constables to explain their non-compliance. In both instances, structural and personnel
changes were satisfactorily implemented as a result.