10 December

Christmas is coming and I’ve just picked up a copy of a British Library stocking filler
Grammar Land, featuring Dr Syntax and Judge Grammar. ‘Every land is Grammar Land;
every man obeys its laws’, says the title page. Not sure about that. But help is at hand.
The quiet coach on the train back from London is a good place to catch up with the latest
edition of the ICO Style Guide.

Good, clear and consistent writing is an important contributor to the way we present
ourselves to our customers. If we come over as remote and bureaucratic in our letters and
publications we contradict the values for which we claim to stand. If we make simple and
all too common mistakes of grammar and punctuation why should our stakeholders have
confidence in our competence as regulators? And if we make a complicated subject even
harder to understand through impenetrable or confusing communications we’re doing the
opposite of what we’re here to do.

We all need to study the Style Guide – and stick to it. Should keep us out of trouble with
Judge Grammar.

And if you are interested, you can also follow up my own list of style disasters by
clicking here.

Meanwhile, I’m preparing for another seasonal ritual – the annual ICO nativity play story.
This year it’s been really big. I was recording something for ITV yesterday, and today I
was interviewed on the Radio 4 Today programme. Obviously, the news release must have
been clear and compelling.

Still on the Christmas theme, it’s party time at the Slug and Lettuce this evening. See you
there.

24 November
I’ve just been meeting with freedom of information decision notice signatories and others
to review the position on our FOI caseload as we approach the final quarter of the
performance year. I am aware that the challenges facing us in terms of the caseload
haven’t gone away. Appeals to the ICO keep on rising and we also need to be lean and fit
to tackle some of the funding challenges in the future.

It’s increasingly important that we make headway and keep pushing to improve the
service we provide, without sacrificing quality. To that end I will be chairing a FOI
Casework Project that will look to streamline how we deal with our FOI cases, with the
group meeting monthly until at least the end of March 2011.

We have agreed that the policy review can be reduced in certain cases, from 1 December
2010, with clear criteria being drawn up for those cases that do require review. Whilst an
automatic review of all cases had strong value for the early years of the Freedom of
Information Act, after five years experience with the legislation we are now be able take a
more proportionate approach to what does and what doesn’t need a policy check.

In addition to this, Ged Tracey has agreed to act as an overseeing mentor to all group
manager signatories.

We remain committed to year end targets of having no cases over one year old, and fewer
than 100 cases over six months old by 31 March 2011. These are milestones that we have
to achieve through being effective, good team workers, all working to one goal and being
focused on delivery of quality outcomes. This is about demonstrating how the ICO values
get real business results.
19 November
A really exciting end to the week, with two significant developments for the ICO – one data
protection and one freedom of information. On the DP side, we succeeded in putting the
Google saga to bed with an undertaking and agreement on our first compliance audit of a
big multinational business. On FOI, we saw our patient work with the Cabinet Office
bearing fruit with the announcement by Francis Maude that the FOIA will be used to
require the publication of usable data sets – what I’m calling FOI 2.0.

The Enforcement and Good Practice teams negotiated the terms of the formal undertaking
and Google’s Senior Privacy Counsel signed up to it overnight. I signed on behalf of the
ICO straight from the 1040 train from Euston. This is the first time we’ve got a big
multinational business to submit to an ICO compliance audit so it’s a significant moment.
Google has also agreed a programme of action to improve awareness and compliance with
their privacy obligations, to apply to their operations worldwide.

Early this morning I was at the Wellcome Foundation building on Euston Road where the
Government was unveiling its approach to the proactive publication of data. Because we
have been closely involved with this initiative we were able to add our spin to this
morning’s announcement and, as a result, our line about ‘the next chapter for FOI’ was
running on Sky News before I’d even said it. I managed to get the point in as a response
to a question about how the rest of the public sector will be made to publish
proactively. ‘Publication schemes, enforced by the Information Commissioner,’ I said
before dashing across the road for the Wilmslow train.

Yesterday I did the rounds of some of the privacy campaigners who have been so critical
of us in recent weeks – Big Brother Watch, Open Rights Group, No2ID and Privacy
International. They have their job to do and we have ours. Advocacy and regulation aren’t
the same thing. But that’s not to say we cannot learn from each other and, on occasions,
work in parallel.

So lots to discuss with Management Board on Monday. Oh, and we moved house over last
weekend – so tonight I’ll be unpacking more crates at home in [Redacted]. Busy or
what?

28 October
A busy day in London with a morning of meetings at the Ministry of Justice. It starts first
thing with Minister of State Lord McNally. Then liaison meetings with the officials who
manage the relationship with the ICO. As well as exploring developments in the
transparency and accountability agenda, I'll be seeking more information on the
implications for us of the Comprehensive Spending Review. I'll be looking to find ways
round some of the micro-managing restrictions we face. And I'll be exploring ways of
making the Information Commissioner's independence more explicit.

We met the trade unions this week to discuss the 2010 pay deal, overdue since July. We're
talking in the context of a public sector pay freeze. I want to get clarity from MOJ about
the operation of the pay freeze, and also about grant-in-aid funding for FOI over the next
four years. If the Government wants us to do more we'll need the resources to do it.

Then over in the Commons there's to be a backbench debate on the subject of the internet
and privacy. I've been busy briefing MPs and ministers on the recent Google streetview
WiFi controversy. There's been some criticism of the ICO for letting Google off the hook
too easily. That's unfair. We've been consistent from the outset about Google's accessing
of personal information from unsecured WiFi routers. What we saw of what they collected
was fragmentary and didn't amount to a significant amount of usable personal data but we
have always said we can use what other regulators' investigations have established to
decide on our next regulatory steps. But hold your hats on for a couple of hours of rage
against the regulator.
Then to the Home Office for discussions on the Government's interception modernisation
programme, the proposal to require internet service providers to keep records of all email,
text and mobile phone traffic - in case it's needed to solve crime or prevent terrorism. It's
not suggested that the messages themselves could be accessed by the authorities. But
who's talking to who, where and when can be significant. The trouble is, are the privacy
safeguards sufficient to overcome the concerns we raised over a year ago? I remain to be
convinced that the authorities have made the case.

Tomorrow we'll be welcoming back some old friends to Wilmslow for the official
inauguration of our new building. Doing the honours for the landlord will be the local MP
George Osborne, who just happens to be the Chancellor of the Exchequer. Former
Commissioners Eric Howe and Liz France will be joining us, as will former non-executive
member of the Management Board David Clarke and two of our current NEDS, Neil Mason
and Enid Rowlands. Watch out too for recently retired Assistant Commissioner Phil Jones.
We're a bit thin on the ground what with half-term and the international data protection
conference going on in Jerusalem. Please help the ICO to give a good impression to our
guests. Naturally, we'll be showing our visitors who we are and what we do. An
opportunity to showcase a modern, efficient and effective regulator, at the forefront of
developments in technology, focused on our customer and stakeholders, and up to speed
on the public policy issues around transparency and accountability.

We might even get T.S. Eliot's spelling right by Friday. If not, it's a question of spot the
deliberate mistake.

Chris

20 October
The Chancellor George Osborne has been unveiling the details of the Comprehensive
Spending Review (CSR), described as the biggest programme of public spending cuts for
decades. This is how the ICO is placed following today’s news.

Three-quarters of the ICO’s income comes from notification fees paid by data controllers.
These pay for our data protection work. But we also receive grant-in-aid from the Ministry
of Justice (MOJ) for our freedom of information responsibilities. We have to keep the two
streams of income separate, although our overheads are ‘apportioned’ between FOI and
DP.

In 2010/11, we have baseline funding from the MOJ of £5 million plus an additional £0.5
million to help us address the FOI backlog. We’ve already had to lop off £160k of this
following the emergency budget. Any further savings we can make this year can be carried
forward against the anticipated cuts required over the four years 2010/11 to 2013/14. By
contrast, our income from notification fees is forecast to be some £15 million.

We do not have a figure yet for how much we shall need to save from grant-in-aid over
the period. But we do know that the MOJ was one of the losers in the CSR – with an
average 6% to be saved each year for four years – while some other departments were
spared the worst of the cuts. That said, we are a pretty small minnow in the MOJ pond.

It’s important to remember that our DP income continues to grow and the tiered
notification fee has given us the resources to carry out our expanded responsibilities. So
we are in a better position today than many equivalent public bodies.

Nevertheless, we have to plan for how the ICO can navigate the choppy waters ahead.

My ET colleagues and I have been thinking ahead to enable the ICO to respond to today’s
developments.
We shall begin planning for 2011/12 to 2013/14 with the aim of maximising our
effectiveness in upholding information rights. Where we need to find savings on the FOI
side of the business we may be able to deploy the resources and expertise that are freed
up on the DP side.

We shall negotiate with the MOJ on the basis that the ICO is a front line service delivering
key aspects of the transparency and accountability agenda.

We will not be undertaking specific freedom of information research projects for the
foreseeable future.

We shall do all we can to continue to recruit, develop and retain the best people. For the
moment, all proposals to fill vacancies must be cleared by ET.

We need to review the way we do things, both in the front line of Operations and Policy
and in the back office of Corporate Affairs, IT, Organisational Development, Facilities and
so on. This is to assure ourselves that we are achieving best value in all we do.

We still need to find savings in the amounts we spend on some smaller items. I am keen
to reach a conclusion in our consultation with the trade unions over first class travel, which
I would like to see withdrawn from 1 December. Earlier this week, we put forward a couple
of other good housekeeping points – around the withdrawal of the double provision of hot
drinks and free car parking at Wycliffe House. Not big bucks, these – but, as they say,
every little helps.

One piece of good news. Our sharp eyed Head of Finance spotted an approval for some
MOJ capital that was due to us for the building. As a result we did not need to finance the
fit out and refurbishment on a lease – freeing up revenue for other things. Good work,
Andy.

I’ll keep you informed of further developments over the coming weeks.

Chris

15 October
The newly decorated Wycliffe staircase sports two more of the ‘writings on the wall’
suggested by colleagues – one thoughtful and poetic, one practical but equally inspiring.
Alongside T.S. Eliot and Little Gidding (you get a better class of literary reference on the
second floor) there is something attributed to a US Navy Admiral, namely: “The most
dangerous phrase in the language is ‘we’ve always done it this way’.”.

The new meetings suite is such an improvement: light, airy, and versatile – and with state
of the art video conferencing kit that should make communication with Edinburgh, Cardiff
and Belfast quick and easy.

The surroundings certainly help to get across messages about being a modern regulator,
responding to the latest developments in the online world and wired in to the transparency
and accountability agenda.

As I said from my car park soapbox when we moved in, it’s really important that we stick
to the protocols about how we use the accommodation:

• clear desk policy;

• office security;
• booking rooms;
• making the most of the new phones; and
• keeping things clean and tidy.
The ICO has to interface with organisations, activities, policies and technologies that are
fast moving and ever changing. That’s why we have to be alert and responsive in our turn
to keep up with what’s happening and deliver the effective and timely interventions that
you’d expect from a regulator that’s really on the ball and part of the action.

7 October
'IEKYF ROMSI ADXUO KVKZC GUBJ' reads the text on the wall in the IT area in Wycliffe
House. The mysterious inscription translates as 'founder of computer science' in Enigma
code and refers to the great Alan Turing who cracked it.

If it hadn't been for people like Turing there might have been no computers and so no ICO
to regulate them, so it is highly appropriate for our decoration scheme. I knew Turing was
a Manchester University reader in mathematics but what I didn't know until yesterday was
that Turing was a Wilmslow resident, living for the last four years of his life at Dean Row.

Work on the reception - the final stage of the project - is very nearly complete. And now
it's time for an official opening. On Friday 29 October at 12 noon, George Osborne,
Chancellor of the Exchequer and our local MP, will be visiting the ICO and opening our new
building. He's the guest of our landlords Emerson who built the extension, and we're taking
the opportunity to show him something of the ICO - although I suspect it will be something
of a flying visit.

As Chancellor, Mr Osborne needs to know about our very current contributions to the
information rights agenda:

• the data sharing code of practice we're putting out

for consultation this week;
• our FOI monitoring, keeping public authorities up
to the mark;
• our thinking on the revision of the EU data
protection Directive;
• work with the Cabinet Office on transparency and
official data sets; and
• compliance audits of Whitehall departments.

No wonder I'm repeating the mantra "what we do is where it's at". I look forward to seeing
you at the opening ceremony - more details to follow soon on ICON - to celebrate this
important milestone in ICO history.

23 August
Information request

It’s inevitable that every now and then someone will test us out by making an information
request about us to see if our response is consistent with what we demand of others. This
has happened most recently with the request for the names and salary details, within
£5,000 bands, of all ICO staff. Although our proposed response is consistent with our
existing policy the disclosure of personal details, albeit work-related is clearly
uncomfortable for some. Our colleagues in Internal Compliance have received a number of
objections to the proposed disclosure from individual members of staff. These have been
carefully considered and taken into account in preparing the ICO response which will be
signed off tomorrow.

Our proposed response has now been modified so that for posts at level A – C we will
disclose job titles, the number of staff doing each job, together with the salary band for
the post, but without naming individuals. For those in posts at level D or higher but
earning less than £50k, we will disclose name, job title and the salary range for the post.
For employees earning £50k or more, we will disclose name, post and salary within a £5k
range.

All those who work in the public sector need to be aware that standards and expectations
regarding the disclosure of this kind of information have changed and are changing.
Increasingly more and more of this kind of information will be routinely published, not just
given out in response to individual requests. In the present case, I want to stress that the
proposed response is in line with our existing policy and that we are not proposing wider
publication (e.g. posting on the ICO website.) Of course, we cannot control what the
recipient of the information in this case will do with it. However, I am prepared to share
with you in this instance that the requester is an MP, quite possibly concerned by advice
we have given relating to the new proposals on the disclosure of MPs’ staff salaries.

Our job is to strike the right balance between privacy and openness. We know from our
own work here that individuals have different personal views on where the line should be
drawn. But in the absence of genuine exceptional circumstances, we have to be consistent
in our approach. One of our values is to be a model of best practice. Part of this is not
expecting others to do things which we would not do ourselves – and therefore we should
do ourselves what we expect others to do. That’s the situation here.

I’d be sorry if anyone were surprised by this, but I’d also be surprised if anyone was
surprised. The trend on openness is one way only and now it’s being further driven by the
Government’s own Transparency Agenda. Therefore I’m starting a consultation on whether
and how our policy on disclosure of information about the ICO and its staff might be
further developed or refined to take account of the shifting scene. Further communications
about this will follow. I look forward to hearing your views.

29 July
Movers and shakers

I’m on the 13.11 train to London again today. I’m due to see the Home Office Minister
James Brokenshire to talk about the regulation of CCTV. Tomorrow it’s Lynne Featherstone
at the Home Office. On Monday, it’s the Cabinet Office Minister Francis Maude.

Then on Friday week, 6 August, we have the Justice Minister Lord McNally visiting the ICO.
He’s going to find us clearing out of Town House and moving into our new accommodation
in the East Wing.

I’ve got moving on my mind at the moment. Not just Town House either. I have managed
to sell my house in Bath after a mere two years on the market, so I’m also busy looking
for a house to rent in Manchester. I’m taking Thursday afternoon and Friday off to do my
packing.

Moving is always a stressful business. But it can be energising too. It’s an opportunity to
work out what is essential and what is just baggage. What to take and what to leave
behind.

Moving into our new accommodation in Wilmslow provides a similar prompt. In many
ways, the smart new building is symbolic of a sharp and modern ICO. But we need to use
the move to reinforce our commitment to the ICO at its best – and dump our bad habits
and institutional clutter. What do I mean? Well, think of the move as a metaphor. Think
about the recent Values communication. Not what we do, but how we do it. What it is v
What it’s not. The ICO needs to be on the move – in more ways than one.

Luckily, the changes we have already initiated put us in a good place. It always feels useful
talking Ministers through what we are already doing at the ICO. It so much fits their
agenda of transparency, accountability, privacy and freedom. I’ll let you know how I get
on.
Finally, a word of warning about security during the ICO move. We have to be squeaky
clean and cannot afford to be caught out losing confidential information or personal data.
An office move is a well-established point of vulnerability: strangers in the building, doors
left open, filing cabinets emptied – or not quite, equipment to be disposed of, storage
devices left around, dropped or misplaced. This morning’s Security Committee heard that
the risks were being well managed. But each and every one of us needs to be on our toes
to avoid unwelcome security incidents. Facilities and IS have good systems in place for
dealing with this and the Security Committee will be publishing some guidance very soon.

The ICO needs to be at its most impressive in these times of change and uncertainty. Let’s
not have ICO being caught out for breaching its own data protection legislation.

<

8 July
There’s a lot of gloom and doom around at the moment, I know; but there are also a good
few reasons to be cheerful just now. I’m on a train to London from Cambridge where the
ICO got a good hearing at the Privacy Laws and Business annual international conference.
We launched the ICO Code of Practice on Personal Information Online. I’m on my way to
the Sky News studio at Millbank for a TV interview about it. Iain Bourne’s been doing some
other media spots, and we've left Mick Gorrill explaining our new powers to fine.

I can’t and won’t pretend to be definitively reassuring about all that is going on with the
coalition government and what it expects of public bodies like the ICO. I won’t pretend to
know all the answers – because I don’t. But I can and do suggest that the ICO is in a good
place, and that while others may be in deep trouble, we are comparatively well placed to
gain in the 'sort out' of the regulators.

So here goes:

1. next week we launch the ICO’s annual report. It’s a

very persuasive account of an organisation emerging from
a period of major change and ready for the future. We’ll
be briefing colleagues on Tuesday and the public launch is
on Wednesday.
2. By the end of Q1 of 2010-11 we had reached a key
milestone in reducing the FOI backlog– a key target for
my first year. There are no longer any FOI cases dating
from before 2009 and fewer than 60 cases that have been
with us for longer than 12 months. Every case received
prior to January this year has been allocated to a case
worker.
3. At the same time, we are coping with a record case
load – both FOI and DP – and we are staying afloat. In
fact, we have even managed to reduce the DP caseload.
4. The new government is prioritising ICO policy
issues, namely: transparency, accountability and privacy.
5. New ministers are keen to hear from the ICO. I’ve
been able to give face-to-face briefings to ministers across
departments.
6. The information rights minister Lord McNally is
keenly interested in what we do – and he wants to come
and see us in Wilmslow in early August.
7. The Secretary of State for Justice Kenneth Clarke
thinks we’ve done well – and wrote to say so.

That FOI backlog is no longer the cloud hanging over everything else. Of course we want
to get the average time to dispose of FOI cases down even further; a year is still a long
time to wait for an answer from the ICO. But we have ideas for doing things differently.
Very soon the backlog will have been eliminated as a problem. Gone. Fini. Finito. And
that’s a major achievement in anyone’s language.

So a big thank you to everybody. Your hard work and commitment have built the platform
we needed to be able to make the case for an effective ICO at the heart of safeguarding
information rights.

Meanwhile, we’re working out how the squeeze in public service budgets affects us:

1. pay. We’re talking to the unions about how we

should apply the pay freeze announced in the emergency
budget with its exemption for the lowest paid. We are also
discussing how we can use such discretion and flexibility
as we have to allocate our limited resources fairly.
2. Recruitment. We’re making the case for the ICO
continuing to fill vacancies. That’s essential to complete
the Project Evolve line-up.
3. Budget. We can see how we would juggle our
spending to meet any cut in this year’s FOI grant-in-aid.
We would make savings without losing people. But I must
stress that as yet we haven’t actually been asked to make
budget cuts.
4. We’re seeking urgent clarification about how
Whitehall restrictions impact on our marketing and IT
plans in the light of the ICO’s independent status and
statutory responsibilities.
5. We’ll plan ahead now for 2011 and 2012 which are
clearly going to be very tight.

As soon as I know more, I’ll pass it on.

Next week I am calling for greater clarity around the funding and the formal accountability
of the ICO going forward. The Information Commissioner needs to be recognised as
independent of government with a more explicit direct reporting relationship with
Parliament – like the Comptroller and Auditor General or the Parliamentary and Health
Service Ombudsman. I believe I am running with the grain of policy thinking on this. There
is widespread recognition that the independent ICO is going a good job – but it would be
better for the ICO’s independence to be more formally underlined and proclaimed.

9 June
This week I’m off to address the Chief Police Officers (ACPO and ACPO Scotland) in
Leamington Spa. There’s so much to cover at their data protection, freedom of information
and records management conference: DNA retention, criminality information, police
publication schemes and so on. One of the ways I get organisations to listen to what the
ICO is saying - and to sit up and take notice - is to explain how we work and what we
stand for. We’re committed, team workers, focused, effective. In other words, I talk about
our values as an organisation. Not just what we do but the way that we do it. The general
approach that informs the specific actions.

Earlier this year, we developed a values statement to go with our mission and vision. Now
we need to make sure we are ‘living the values’. Are we in fact a model of best practice?
Are we alert to the perspectives and needs of all our stakeholders? Are we fair? Are we
always learning and developing professionally?

On the team working theme, I’m kicking off a series of ICONNECT sessions to launch the
communication of the ICO values. I’ve invited managers to one of two ICONNECT ‘brief the
briefer’ sessions on Wednesday 16 and Friday 18 June At those sessions, I’ll be asking
managers to book in their own team sessions, so we all get the message and a chance to
discuss how we’ll make the values part of every day life here at the ICO. And, remember,
the values are the new competencies for performance management purposes going
forward.

I’m keen to use the ICONNECT briefing process to communicate better with colleagues
generally and to collect staff input into our plans.

Last week, I was talking the ICO values with the new Minister of State at MoJ Lord
McNally. The Minister declared himself most impressed with the changes at the ICO. The
ICO branded mouse mat and coaster – coming soon to your desk via the ICONNECT
process – were helpful visual aids to make my point: the ICO is building an effective
platform to be a key partner in upholding information rights. An important point to be able
to make as the new Government speaks the language of transparency and accountability.

As Tom McNally, our new Minister was MP for Stockport from 1979-83 and he is keen to
pay us a visit before too long. I get to meet the new Secretary of State Kenneth Clarke
next week (with a few hundred others at an MoJ reception.)

As work progresses with our new Wilmslow accommodation, we’ve started to see the
‘writing on the wall’ – the corporate branding scheme that highlights some of the things we
are about. We’ll shortly be announcing the results of the competition for quotable quotes
to appear alongside our mission and values. On the first floor at Wycliffe there’s an
ominously empty space above my workstation. ‘Big Brother is watching you,’ would just
fit. Just so long as it doesn’t turn out to be the original writing on the wall from the story
of Belshazar’s Feast – ‘Thou are weighed in the balance and found wanting.’ Not very
motivating, that, I’d say.

27 April
I’ve been away in Scotland for 10 days. Now I’m rushing to catch up with myself before
flying off to the European Data Protection Commissioner’s Conference. Last year the ICO
hosted the event in Edinburgh. This year we are the guests of the Czech commissioner in
Prague.

I am trying to be pretty selective about the conferences I attend and the invitations I
accept. But the fact is that international co-operation is important and together we can
get more done. Last week’s initiative on Google, for example, was the more powerful for
involving a number of data protection commissioner colleagues. The EU Commission has
given notice that they are reviewing the data protective directive. We need to keep in
touch with partners and make our voice heard.

Today we had a good meeting of the Management Board. I was able to update our non-
executive colleagues on the latest developments in Project Evolve.

• Policy Delivery, Strategic Liaison, Good Practice

and Enforcement are now functioning as part of the new
structure. Of course there are still decisions to be made,
processes to update and posts to be filled, but a lot of
progress has been made.

• Recruitment to the new Evolve structure continues.

More details can be found in the ‘Current Vacancies’
section of ICON.

• First Contact and Complaint Resolution may take a

little longer to get established as the level E and F
positions need to be filled before we start to move fully to
the new structure. More details will be on ICON as soon as
they are known.
This week we are launching the staff picture gallery on ICON. The idea is to aid
cooperation and team work by putting names to faces and vice versa. A number of
colleagues have taken advantage of the offer to have a ‘better’ photo posted. I can live
with my ID picture: not particularly flattering, but fit for purpose. I’m satisfied that the
photo gallery does not breach anyone’s data protection rights – and we’ve established that
we would not expect the photos to be released to outsiders under FOIA. I am sure this
new ICON service is going to be a real help. No excuse now for not knowing everybody’s
name.

Staff gallery

14 April
A brief note from me before I head off to Scotland to get married. Not at Gretna Green, I
hasten to say – even though a Graham ancestor did a flourishing trade as blacksmith and
‘marrying priest’ there, developing the Sark Bank Hotel as his business expanded. But
please spare a thought for my fiancée [Redacted] and me at 2.00 pm on Saturday 17
April, Edinburgh.

I’m on leave from lunchtime on Thursday, back in on 26 April.

Speaking of Smiths, the two Deputy Commissioners will be in charge in my absence. The
ICO needs to stay alert to what is happening around the election campaign. We need to
act decisively where data protection rules appear to be being breached by the parties. And
we need to be careful about ourselves becoming the story as information rights become an
issue in the campaign.

Now that the Evolve structure is almost in place I am turning my thoughts to the issues
around our strategy, plans and objectives. The draft corporate plan is out for consultation,
our budget is with MoJ for approval, and we now need to catch up with detailed business
plans and SMART objectives for each area.

Meanwhile, how do I learn to waltz in the next 48 hours?

1 April
As we pack up for the Bank Holidays, I want to update you on the latest about Project
Evolve – because we have a busy few weeks ahead.

ET has now given consideration to the representations both of individuals and of the trade
unions in response to our proposals for the staffing of teams in Operations and
Policy/Strategy in our new structure. The consultation process, which ran from March 8,
covered both the proposed new structure and the proposed roles for individuals within it.
In other words, we covered both the general and the specific. The vast majority of
comments and queries related to the impact of the changes on individual staff. Comments
on the structure were broadly supportive of our plans and we have made some changes to
some job roles as a result of points made. Comments from individuals about their
proposed roles and ‘slotting’ were addressed in discussions with the staff concerned. As a
result, a number of changes were made to our proposals in order to address individuals’
concerns.

We have also met formally with the trade unions and sought their comments. The most
recent meeting was yesterday morning.

We believe we have consulted thoroughly and are in a position to confirm the position next
week – both the overall position and the impact on individuals.

Accordingly, we intend to send everyone affected a letter on Tuesday setting out where
their new role slots into the new structure. During next week, staff will be given further
information on what will be happening in their areas, stage by stage, as we move from the
current to the new structure.

Also from 6 April, Steve Wood and Jonathan Bamford assume their new roles of Head of
Policy Delivery and Head of Strategic Liaison. Staff in Policy and Strategy will report to
Steve and Jonathan in their new roles.

Although we will now have the confirmed new structure in place from 6 April, it cannot be
fully implemented in practice until we have completed a number of recruitment exercises
to fill vacancies in the line up. The starting gun for these recruitments will be advertised on
ICON on Tuesday and the vacancies will provide opportunities for staff at levels D, E and F.

So watch out for more after the holiday – and many thanks to everybody who participated
in the consultation. It’s taken us nine months of reviewing and restructuring – but I think
we are getting to a good place and a good platform for the ICO’s future effectiveness,
efficiency, relevance and reputation. That’s going to stand us in good stead in the exciting
period ahead. It will have been worth all the upset and anxiety – so thanks for bearing
with us.

30 March
Justice Minister Michael Wills has confirmed a modest extension of the freedom of
information regime to include a small number of additional public authorities – ACPO (the
chief police offices’ association), UCAS (college admissions), the Financial Ombudsman
Service and Academy Trust schools. The news came in a Ministerial Written Statement
earlier today and we’ll be talking to the Ministry of Justice about the details of
implementation, publication schemes and so forth. So far, we know that the order will be
subject to debate in both Houses of Parliament, and is currently expected to come into
force October 2011, to allow time for the public authorities to prepare themselves. Read
the MoJ media release here.

We should welcome this modest extension of FOI. The proposal had been consulted on so
it’s not a surprise. It’s a move in the right direction to promote openness by public bodies.
But it will mean more work for the ICO.

I chaired a meeting of FOI signatories this morning. We have made significant progress in
clearing the oldest cases. But as fast as we clear up the old cases the number of new
applications to the ICO is at record levels – and Internal Compliance are also having to
cope with rising numbers of FOI applications to the ICO as a public authority in its own
right – often of the ‘what’s happened to my complaint?’ variety.

The speed up in tackling the backlog has been achieved by a lot of hard work by
colleagues. The message is getting through to public authorities that they have to speed
up too. But apart from running in top gear for the past several months, we haven’t yet
done anything fundamental about the way we approach freedom of information
complaints.

With Project Evolve we have an opportunity of rethinking our processes to develop a more
sustainable approach to customer delivery. That’ll be for after the Easter holiday. We’ll
need a combination of process re-think, smarter working, and a tough approach to public
authorities if we are to cope with the increasing caseload. Meanwhile, it’s almost year end.
Must get that 2009 Decision Notice signed or it’ll be me that’s the weakest link. I wish
everyone a good and relaxing Bank Holiday break when it comes.

22 March
They did it! Work started on refurbishing Wycliffe House on 1 March. Three weeks later, 21
of us are working in the spanking new decant area in the West Wing – and the builders
have started knocking down the walls of the old management corridor upstairs. The move
went like clockwork – a lot of work by a lot of people to make sure things went smoothly.

The business of clearing up and packing up is useful as well as necessary. Decluttering the
office has the effect of a good spring clean. I heartily recommend it.

It’s going to be a busy week. Jonathan Bamford and I have got another Select Committee
to do in London tomorrow and there are a lot of meetings and presentations besides. Then
Friday is the deadline for consultation on our Project Evolve plans for Operations and
Policy/Strategy teams. Don’t forget to raise any remaining concerns with managers. We
want to be able to let people know how things stand straight after the Easter break.

We had a Project Evolve board meeting on Friday and discussed the proposed staff photo
gallery. We confirmed that the photos held will be personal information in respect of any
freedom of information requests from outside the ICO.

17 March
We know from Charles Darwin that evolution took a long time. Sometimes it must seem
that our Project Evolve has too, comparatively speaking at least. But now the full proposals
for Operations and Policy and Strategy are complete and have been put to staff individually
and collectively. Once everyone affected had been briefed last week we posted the
complete picture on ICON.

Now we are in consultation mode. Individuals have the opportunity of a conversation with
an appropriate manager. Yesterday we met the trade unions. The consultation phase
finishes on Friday week, 26 March – and we aim to confirm the new team structure (with
any amendments) by 1 April, so that we start the new performance year with the new
shape of the ICO defined.

The whole purpose of this consultation is to give everyone the opportunity to engage with
us about our proposals. The consultation includes what the proposals mean for individuals
as well as feedback about the overall structure – so we are keen to hear your views on
both aspects. If you have any concerns about the proposals in relation to your future role
and what the proposals mean for you, you need to raise these now. We will try to resolve
any queries, concerns and objections during the consultation period.

Please do not wait until after the end of the consultation to tell us that you are not happy
about the role proposed for you. You need to raise this with the appropriate head of
department or HR (and your trade union if you are a member) as soon as possible and
arrange a meeting. If you do not raise issues now we will presume that you are happy with
the proposals – and we’ll lose the opportunity of making adjustments to our plans ahead of
the results of the formal ‘slotting’. Of course we may not be able to accommodate
everybody and there may be disputes and grievances further down the line. But the main
job of suiting people to posts in underway now – and requires staff input.

There’s a role for everyone and good opportunities for career development as the ICO
expands. I am glad to say there are no redundancies.

5 March
What a week! When I signed the Ashcroft Decision Notice at the end of January I little
thought I was lighting the blue touch paper for a delayed explosion of such political
fireworks. And life at the ICO itself has not been without excitements of its own.

The construction work on the new building and within the west wing of Wycliffe is racing
ahead. Colleagues working on the accommodation project are working out how we can
best use the new spaces that are being created. The work is a symbol of a new ICO under
construction. I’ve been most impressed by the quiet efficiency of Facilities who seem to
have an answer to every problem.

Then there’s the new ‘corporate identity’. People appear to like it – and the fact that we
are not spending a lot of money re-stocking with the new logo. I think the whole identity
project has been brilliantly led and delivered – and the new ‘look’ is playing very well with
the external stakeholders I’ve been quizzing this week.

The Data Protection Officers’ conference in Manchester on Wednesday was a sell-out and
yesterday I had a good reception at the Direct Marketing Association’s data protection
compliance conference in London. We launched initiatives on a ‘privacy dividend’ – a way
of spelling out to chief executives and directors of finance how data protection makes
sense in business terms; and also a reminder to the politicians that data privacy rules
apply just as much to election campaigning as to commercial marketing. They have been
warned!

I like it that these projects – accommodation, re-branding, and the big conferences –
involve so much team working across the ICO. That’s the way it has to be from now on.

Meanwhile, we are working through the outstanding FOI cases from previous years. The
backlog is shrinking nicely. But it’s nail biting time as we race for the tape - our objective
of clearing all the really old and overdue cases by 31 March. Again, it’s about teamwork.

Next week, we’ll be rolling out our plans for the team structures in Operations and Policy
under the banner of Project Evolve. That marks the next stage of consultation, involving
both individuals and the trade unions. I had a number of expressions of interest in the
project manager role I was advertising. I have decided to appoint Adam Stevens from
Internal Compliance to work to me for two days a week to help deliver Project Evolve over
the next six to eight weeks.

Sight-reading the Mozart Requiem in Glasgow tomorrow will be a doddle compared with
everything else that’s going on. Then next week I need to get cracking on sorting, tidying
and packing. I have to be out of my office in a fortnight and the diary is looking a bit
challenging between now and then.

1 March
There’s an old saying about March coming in like a lion – and this month at the ICO
certainly comes in with a bang.

We’ll be unveiling the new look teams that will operate our more integrated organisational
structure in Policy and Operations.

And today work starts on the refurbishment of Wycliffe House, creating a new modern
work space for ICO people.

Also today we are unveiling the new look for the ICO – our corporate identity. I’ll be
introducing the new ID at a briefing with the designers who developed it at Revolution
from 12.00 to 1.00pm.

This is not some fancy corporate re-brand costing millions. We’re being careful to migrate
to the new look over time, without having to throw out everything of the old look. But the
aim is to communicate to our stakeholders that we are modern, businesslike and customer
focused – as I like to say, ‘both dotting the ‘I’s and getting to the point.’

We’ll be using the overall ‘look’ in our new Wycliffe accommodation. The ‘writing on the
wall’ project invites your participation to identify some inspiring and relevant quotes to be
incorporated in the decorative programme. Thoughts like ‘sunlight is the best
disinfectant’, for example. (That’s from a US Supreme Court Judge, Justice Lewis
Brandeis, since you ask.)

I think there’s got to be something for us between the motto of the New York Post Office
quoting Herodotus (‘Neither snow, nor rain, nor heat, nor gloom of night stays these
couriers from the swift completion of their appointed rounds’) and the art work in the foyer
of the Financial Services Authority in London (‘You’ve got a lot of nerve to say you are my
friend’ – Bob Dylan.)

If March comes in like a lion it’s supposed to go out like a lamb. I can’t promise any let up
as we advance towards an election, a new Parliament, possibly a new government – and
certainly new challenges to which we’ll need to respond. The good news is that we’ll be
better placed to play our part as ‘the authoritative arbiter of information rights’.

15 February
It’s the start of another busy week as we continue to make the changes the ICO needs for
its vital role upholding information rights.

We’re moving forward to the next stage of Project Evolve. For those who have already
been asked to comment on the proposed structures for the Operations and Policy functions
the closing date for comments will be 24 February. Then we’ll roll out a firm proposal to
staff and the unions for consultation.

Meanwhile I’m looking for a Project Manager to help with the increasingly complex and
detailed business of implementation. Could this be you?

We’ll be advertising for the remaining Heads jobs this week – Head of Customer Contact,
Head of Good Practice, and Head of IT. This last vacancy was to have been covered by an
interim manager, but following a disappointing external response I’ve decided to try
again. Meanwhile, Dave Wells will work with Lesley Bett to cover this very wide field of
responsibility until I can make a permanent appointment. At that point Lesley will move
across to the role of Head of Internal Compliance.

On Friday, there will be an opportunity to see our plans for a new look Wycliffe and what
the new East Wing will look like when it’s finished. I’m just waiting for the final approval
from the Ministry of Justice and then we can unveil the programme for the refurbishment.
We’ll need to get on with this so it’s not too early to get ready for any upcoming moves by
sorting out and throwing away.

Then next week we’ll be unveiling our new corporate identity/logo/look. It’s classy and
modern – in fact everything the 21st Century ICO needs to be. It says we’re changing
and, look, we are.

27 January
I’m grabbing a moment between meetings to write up some of what I have been at the
last seven days.

Last Wednesday morning, I was in Whitehall for the Cabinet Secretary Sir Gus O’Donnell’s
weekly meeting. ‘Wednesday Morning Colleagues’ is the gathering of all the Permanent
Secretaries. They are a powerful and formidable lot – and not a little scary.
I was there to explain what we are doing at the ICO and how that impacts on what we
expect from public authorities and data controllers, great and small. I said we wanted to
be partners in delivering information rights – but that we would be tougher with anybody
we believed was trying to ‘game’ the system. I suggested they would ‘taste the difference’.
(You can take the boy out of the ASA …)

I was introduced by the Perm Sec at the Ministry of Justice Suma Chakrabarti. Once again,
he was very complimentary about what he’d seen on his visit to Wilmslow before
Christmas. There was a very positive response to my brief presentation and I then had to
respond to questions and comments from no fewer than six Permanent Secretaries. So
they were listening.

David Bell of the Department of Children Schools and Families said there had been a
positive change of tone from the ICO and he asked me to feed that back to staff. Jonathan
Stephens of the Department of Culture Media and Sport had noticed that the ICO was
speeding up. The same point was made by Leigh Lewis of the Department of Work and
Pensions and Alexis Cleveland of the Cabinet Office. Sir Gus was friendly – but indicated
that the relationship between Whitehall and the ICO will always be robust. But he too gave
us credit for getting things moving.

I’ve been taking the opportunity before everyone and everything goes into ‘purdah’ for the
General Election to meet politicians to brief them on what we are doing and what we might
do in the future. Again, there is a very positive feeling abroad. Information rights are high
on everybody’s agenda and the ICO is only going to be asked to do more in the future. I
say we’re up for it – but we’ll need proper resourcing.

More good feedback from HMRC about our ongoing audit work. HMRC are so big and
important that they have two Permanent Secretaries – and I’ve met both of them and their
chairman in the space of a fortnight.

On Thursday, Iain Bourne and I met up with Brad Smith, Mircrosoft’s General Counsel. He
was on his way to Davos. Then yesterday it was a round table with data protection
professionals and lawyers on the fifteenth floor of Citibank’s HQ in Canary Wharf. I was
glad I had Geri Dersley with me to field some of the technical stuff. Hearing from the
people who have to make data protection work across global businesses is a reminder that
what we are doing is more than just theory. I came away with a long list of suggestions for
what the ICO should be doing to help.

Early train from London this morning and my slot at the corporate induction day at
Wilmslow. Among the newcomers were our two new Non-Executive members of the
Management Board – Enid Rowlands and Neil Masom. We had a good Management Board
meeting on Monday with lots of positive suggestions for the corporate plan I’m working on.

Then back on a train to Edinburgh for the ICO reception at the Scottish Parliament this
evening. With all this travelling about, I am glad of the remote working facility that goes
with my laptop. That way I can keep in touch with the office when the diary goes crazy
busy – and finally send this from the waiting room at Preston station.

6 January
Happy New Year everybody! I hope you had a good break and are ready and raring to go.
There's lots to do - and lots of snow to stop us getting started.

What a start to 2010! On Tuesday I donned woolly socks and hiking boots and made good
use of my ski pole to get to the London train for my date with the Justice Committee at
Westminster. We had at least six inches of snow in central Manchester. Stephen
McCartney joined the train at Wilmslow. Together we briefed MPs about data protection
issues in Europe. Earlier in the day at Westminster Michele Voznick had formally laid our
report on Jack Straw's second FOI veto of an ICO decision notice. Our carefully phrased
response was raised in the Commons at Question Time and the Justice Committee wanted
to know more.

MPs also wanted to ask about our FOI caseload following the critical adjournment debate
before Christmas. Thanks to the efforts of so many ICO staff I had an encouraging story
to tell. In the first nine months of 2009-10 we closed more FOI cases than in the whole of
2008-09. Since April, we have reduced the outstanding caseload by 30% compared with
the same period last year. Cases more than a year old are 52% down. Cases more than
two years old are 70% down. Despite complaints to the ICO being up 21% compared
with the year before, FOI case closures are up 43%.

This is an encouraging early result from the coordinated drive of FOI policy and operations
staff to tackle the backlog. Some long outstanding decision notices have been making
news. And a lot of the comment on the fifth anniversary of FOI has focused on foot-
dragging by public authorities - not by the ICO. I have a date with Whitehall Permanent
Secretaries later this month to reinforce the 'get a move on' message.

But we are by no means out of the woods yet. There are still around 40 very old cases to
be completed by the end of this month and we need to set targets for the final quarter.
But we should have a better story tell in the annual report. Thanks to everybody involved
in turning things around.

Today I'm back on the train to London meet the Society of Editors to reassure them about
the impact of the proposed custodial penalty for reckless breaches of the Data Protection
Act. It's so not about investigative journalism. Scandals involving the blagging of
personal information for marketing purposes or debt collection services certainly concern
newspaper readers. They wouldn't be amused to know that it was the newspaper lobby
that was standing in the way of an effective deterrent to the murky trade in personal
information. The MOJ consultation on the proposal ends this week. It's worth fighting
through the snow and ice to secure increased section 55 powers: realistic fines for
organisations and the threat of prison for rogue employees.

I hope we can soon get back to normal weather-wise. Meanwhile, thanks to everybody
who is helping to keep the office going.