2011 Annual Report of the Interception of Communications Commissioner
I outlined earlier in my report that a traffic light system (red, amber, green) has been adopted
for the recommendations that emanate from the inspections. This enables public authorities
to prioritise the areas where remedial action is necessary. This year 261 recommendations
were made by my inspectors during the local authority inspections and this is an average of 6
recommendations per public authority (if all NAFN users are treated as one). Figure 12 shows
the breakdown of recommendations by colour.
Figure 12 – Recommendations from 2011 Local Authority Inspections
Red
5%
Green
48%
Amber
47%
Although only 5% of the recommendations represented serious non-compliance with the Act and
Code of Practice, these recommendations have highlighted some serious faults in the approval
part of the process. It is important however, to recognise that these serious faults only relate to
a very small number of the local authorities inspected.
It is also worthy to note that my inspectors identified 77 reportable errors during the 2011 local
authority inspections that had not been notified to my office. The causes of the vast majority
of these errors, which are related to the DP part of the process are explained below. This is
a large number of reportable errors that would otherwise have gone unreported. However
it is again important to recognise that the 77 errors all relate to a very small number of the
local authorities inspected (9 of the 110 local authorities inspected), and therefore so do
the associated compliance issues. I am pleased to report that all of the local authorities have
responded very positively to their inspections and I have been provided with assurances that
their recommendations have been implemented and that corrective action has been taken where
necessary. The findings however do highlight the importance of the inspections.
“these recommendations have highlighted some serious faults in the approval
part of the process. It is important however, to recognise that these serious faults
only relate to a very small number of the local authorities inspected”
First, my inspectors were extremely concerned to find that in two local authorities the
communications data that was acquired had not been approved by a person of sufficient seniority
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