Posted by Gillian McNeill on the 10th May, 2023
At CALL Scotland we are aware that many services in Scotland providing Augmentative and Alternative Communication (AAC) are being asked to provide Data Protection Impact Assessments (DPIAs) to comply with UK General Data Protection Regulation (GDPR). Way too many acronyms! The good news is that Scottish Government have recently made a shared DPIA document available, so that those working in health to provide and support for AAC, can adapt and use it.
In accordance with the UK GDPR Article 35, DPIAs are mandatory for new processes and projects where people's personal data is being processed. This data can come in many forms and is capable of identifying an individual, whether that is by itself or in conjunction with other data, which then taken together could identify someone.
Many AAC systems whether printed or higher tech such as Voice Output Communication Aids, to be useful and effective for AAC Users, require collection and storage of personal information and communication messages. This meeting the criteria for a DPIA, as...
Scottish Government through the work of their AAC Team and Information Governance and Assurance Unit, have collaborated with the Fife AAC Team (FAACT) and NHS Fife to produce a 'streamlined' DPIA.
The document is helpfully based on the DPIA written and used by the FAACT service. It provides information that will be common to many other providers, allowing consistency of information and avoiding duplication of time and effort. The purpose of sharing it centrally is for it to be used a starting point for others to adapt and make specific to their own local needs. Thus supporting the AAC legislation.
Scottish Government Digital Health & Care - NHS Scotland Speech and Language Therapy DPIA
Screenshot of the website page where the DPIA can be accessed. Scroll down the page and use the keyword search and 'speech and language therapy' to find it.
A centralised mailbox hosted by Scottish Government, if support about the DPIA is needed.
Email: dhcig@gov.scot
This includes support to assist with completion of Part 7 section titled 'Documentation Table.' As some information for his section has been removed, due to the potentially sensitive nature, a direct request for this information can be made.
Plans are underway for guidance to be developed to accompany the DPIA, to facilitate ease of understanding and use. This to include guidance on adding appropriate local information.
Also, some good news for those working in the education sector, is that Scottish government are having discussions with education around support for similar issues, including those arising from use of Boardmaker symbol software.
We are eagerly watching that space!
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