Right to be informed – Privacy Notices. Where personal data is created or received by one of the parties, they are responsible, as required by law, for making the data subject(s) aware within a reasonable time frame that the organisation holds the data, what they will do with it, how long they will keep it, and who they will share it with (such as under this DSA). This is normally done through a privacy notice, whether written or verbal. Organisations agree that they will adhere to the transparency requirements of the UK GDPR and will issue appropriate notices which inform the data subject that the information will be shared with the parties under this agreement. In some cases, it may not be appropriate to let a person know that information about them is being processed and shared. Consideration should be given to whether notifying the individual may place someone at risk or prejudice a police or safeguarding investigation. In these circumstances, the parties need not inform individuals that the information is being processed/shared; but should record their reasons for sharing information without making the individual aware. We must be practical and recognise that whilst privacy information is required, it should be suited to the circumstances. It is unlikely to be useful to hand out full privacy notices during an incident, but there are options available. Privacy information can be provided on websites and within emergency preparedness plans, so the public are aware overall of the types of data shared during emergency incidents. Parties to this agreement must ensure they create suitable privacy information as part of their emergency preparedness, that can be employed during an incident. For example, a short, clear explanation for display in rest centres, and privacy information given at the same time as follow up support. Where deemed appropriate, template privacy notices will be developed to provide a standardised approach across London. The London Humanitarian Assistance Framework includes guidance and templates.
