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London: Practitioner
Starts 2 October 2018

Update: Nov 12
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One possible way in which this idea could work well would be to present it as an option for those who submit complaints to agree in advance to the streamlined decision process.

Alternatively, left solely to the ICO's own choice, a streamlined process could work well if used as in these three examples:

1. Your case is so utterly without merit that we won't waste our time telling you anything other than, politely, "go away". (Of course written MUCH more nicely than that, but equally briefly).

2. Your case has merit and we feel your pain, but refer to x, y, and z for self-education as to why you lose. (Again, of course written much more nicely than that).

3. Your case has various nuances, and we feel your pain and your confusion, we refer you to x, y, and z for details to understand why, pointing out specifically a, b, c, and q. (But not bothering with immensely detailed legal text, on the judgment call that this particular plaintiff, based on how he wrote his complaint, was looking for understanding rather than revenge/ a court case).

In other words, the streamlined process would be used on abusive cases, obvious cases, and non-obvious cases which do not appear likely to result in court challenge if given a clean answer.

This is a bit like the "appropriate technical safeguards" guidance included in or implied by nearly every privacy law on earth, allowing for sensible effort-setting by the responsible party. The balance against abuse or erroneous use of the streamlined process is, as in the "appropriate safeguards" case, the opportunity for the aggrieved party to appeal to tribunal.

Jay Libove, CISSP, CIPP

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