ICO communications and external relations strategy by dfsiopmhy6

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									Strengthening our
position
ICO communications and
external relations strategy
Three year plan 2009-12




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Contents

1        Summary
2        Our communications commitment
3        Where we were
4        What we want to achieve: objectives and measures
5        How we will do it: our approach
6        Messages
7        Audiences and how we reach them
8        Creative treatment
9        Distribution
10       Budget and resource
11       Review and evaluation


Appendix one: sources
Appendix two: key indicators
Appendix three: action plan




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1 Summary
1.1      This strategy has been updated to reflect latest market research
         results. It supports the ICO’s Corporate Plan and other supporting
         documents, including the Data Protection Strategy, HR strategy and
         enforcement strategies. The strategy has been compiled using
         feedback from customers (including market research, evaluation and
         management information) and ICO staff (including strategy workshops
         and staff survey information). The strategy is a working document for to
         determine the ICO’s communications activities and, in particular, the
         work of its Communications and External Relations department: it will
         change to reflect business need and to adapt to communications
         developments.


1.2      The ICO’s communications have been successful. We have achieved
         the process targets we set ourselves and are doing well against our
         measurable communications objectives. We are now in a position to
         make choices about the direction our communications should take.


1.3      The emphasis of this strategy is customer focus: listening to the needs
         of our audiences and responding to them. It aims to give them relevant
         information, in the format they need it and in a place they will see it.
         This will help them to protect personal information and promote access
         to official information, and to enable people to exercise those rights. It
         makes the best use of new technology and emerging channels, to keep
         up with customer expectations; it also sharpens our messages. In
         addition, it has the more ambitious aim of making good information
         rights practice a social expectation.


1.4      The ICO’s positioning has moved on. While we still aim to be credible,
         robust and helpful, we feel these characteristics have been built into
         our corporate approach. Our aim now is to be recognised as the UK’s
         independent, influential and practical authority on information rights and
         responsibilities, making a difference to people.



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1.5      Our new communications objectives are:


Educating and          •     Maintain awareness of rights (among individuals)
influencing            •     Raise awareness of obligations (among organisations)
                       •     Encourage good practice (among organisations and
                             individuals)
                       •     Maintain the reputation of the ICO (among stakeholders)
                       •     Confidence in organisations’ handling of information (among
                             individuals

Resolving problems     •     Increase customer satisfaction

Enforcing              •     Raise awareness of the ICO as the enforcing authority
                             (among organisations)

Developing and         •     Increase staff engagement
improving


         Each objective has a key indicator (or set of key indicators) to check
         our progress. Where possible, we measure outcome (the difference we
         have made).


1.6      Our priority communications channels remain media and online. We
         have done a lot of work to improve our internal communications and to
         plan our stakeholder relations strategically: these are areas we will
         continue to develop.


1.7      Progress against this strategy will be reviewed quarterly, as part of the
         ICO’s business plan reporting methods and as part of the ICO’s
         quarterly evaluation report on communications. The strategic direction
         will be reviewed annually.




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2 Our communications commitment
2.1      Aim of this strategy


The aim of this strategy is to ensure that the ICO fulfils its statutory duties and
its corporate plan commitments to promote good practice, awareness and
understanding of privacy and openness issues. This covers the legislation we
oversee: the Data Protection Act, Freedom of Information Act, Privacy and
Electronic Communications Regulations and Environmental Information
Regulations. The strategy sets out how the ICO will achieve its aim of being
independent, influential and practical, giving clear information and advice to
appropriately targeted audiences.


2.2      What good communication means to the ICO


•         Good communication is essential to deliver our Corporate Plan.
•         Good communication is defined as two-way, appropriate to the
          audience, medium and message, and is in correct, clear language.
•         Good communication is also honest, relevant, timely, appropriate,
          useful, inclusive and authoritative.
•         Good communication can also be persuasive.
•         Good communication is tailored to suit the audience.
•         The term communication covers all written and published materials, as
          well as oral and face to face communication by ICO staff.


2.3      What the ICO will do


         Where appropriate, relevant and proportionate, we will:
•         Research opinions of our communication and measure its
          effectiveness.
•         Consult with our customers and stakeholders (for example, on
          significant matters of policy, or changes to the way we do things).




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•         Adopt a house style guide covering corporate identity and written style
          of published communications.
•         Reflect our legal and moral responsibility by making materials
          accessible and available.
•         Distribute the information appropriately.
•         Promote equal opportunities in our communications.
•         Follow the government Code of Practice for Public Consultation and
          other relevant guidance.


2.4      How we will implement it


•         The Executive Team is responsible for ensuring good communications
          are championed and implemented in each department.
•         Staff will be made aware of their communications obligations.
•         Good communication will be considered as an aspect of performance
          assessment, in line with our competency framework.
•         We will support this strategy with training.
•         ICO projects, initiatives and plans will include communications
          considerations.
•         This strategy will be supported by relevant policies and procedures.


2.5      Charges


•         We will not normally charge for materials, although some documents
          (such as the Annual Report) may have a cover price.
•         We may charge for some bulk print runs (for example, if a commercial
          organisation wants to distribute several thousand of our leaflets to their
          customers).
•         We will not normally charge for ICO events, although some may carry
          a fee.




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2.6      Accessibility


•         The ICO’s main language is English.
•         We will adhere to the ICO’s Welsh language, Northern Ireland and
          Disability Equality Schemes.
•         Material in other languages will be published in accordance with our
          translation policy.
•         We will make our publications available in some other languages and
          accessible formats (such as Braille or tape) on request, and produce
          some documents in easy read format.
•         We will publish most of our materials, and any available translations,
          on our website.
•         We will make use of available technology to ensure our website is
          accessible to government standards.




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3 Where we were
3.1      Performance against former objectives


In 2006, the ICO identified six communications objectives, with measures to
track our success:
•         Encourage good practice
•         Raise awareness of the ICO
•         Maintain awareness of rights
•         Increase confidence
•         Increase customer satisfaction
•         Increase staff satisfaction.


Our performance against these objectives has been good. Awareness of
information rights among individuals and organisations is the highest ever –
we now need a more relevant measure for organisations. Awareness of the
ICO is also the highest ever, among organisations and individuals. We are
well respected internationally, and our data protection communications work is
considered to be among the best in Europe. Confidence in the rights is
volatile, and low for data protection, especially as concern is rising that people
have lost control over their personal information; we need a more pertinent
measure for confidence for both freedom of information and data protection.
The ICO is taking steps to improve the two key drivers of customer
satisfaction – response times and keeping customers informed. From a
communications perspective, we have responded to feedback by improving
our website and introducing plain English standards, and we now need to
concentrate on anticipating customers’ information needs. While we have no
single key measure for encouraging good practice, media coverage has risen
and feedback on our website and publications is positive. By using
management information to create targeted campaigns, we should be able to
develop better measures in the future. Staff satisfaction has dropped
considerably; while internal communications has improved, the ICO needs to




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work to tackle factors such as pay issues, and to improve trust in senior
management.


3.2      Background


In January 2005, the ICO agreed a new approach to communications by
adopting its first three-year ICO communications and external relations
strategy. The strategy moved ICO communications from an advertising-led
approach towards an emphasis on two-way communications, reputation
management and on building relationships. It outlined the following goals:
•         Create clear streams of communication
•         Prioritise web work
•         Prioritise media work and start storytelling
•         Develop internal communications
•         Manage stakeholder relations.
The ICO has done a great deal towards achieving these goals, including
launching a new website, an intranet and staff briefing system, introducing a
new corporate identity and plain English, starting an e-newsletter, adopting a
stakeholder relations strategy, doing more proactive media relations work,
improving our planning, and sharpening our evaluation and reporting.




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4 What we want to achieve:
communications objectives and
measures
4.1      The new communications objectives
Educating and        •    Maintain awareness of rights (among individuals)
influencing          •    Raise awareness of obligations (among organisations)
                     •    Encourage good practice (among organisations and
                          individuals)
                     •    Maintain the reputation of the ICO (among stakeholders)
                     •    Confidence in organisations’ handling of information (among
                          individuals

Resolving problems   •    Increase customer satisfaction

Enforcing            •    Raise awareness of the ICO as the enforcing authority
                          (among organisations)

Developing and       •    Increase staff engagement
improving


While the communications objectives identified in 2006 remain relevant and
appropriate, we need to make some changes to them to ensure we develop
our communications to meet challenges over the next three years. The
revised objectives and measures all support the ICO’s aims, vision and
values, as articulated in the Corporate Plan and the Data Protection Strategy.
They contribute to the ICO’s focus areas of educating and influencing,
resolving problems, enforcing, and developing and improving; they also
support the ICO’s stance of being independent, influential and practical. The
success of the ICO’s communications and external relations work will be
tracked by measuring each objective with a key indicator. Wherever possible,
we measure outcome (ie what difference did it make?) as this is the best
indicator of progress. However, we also monitor output (for example, the
number of news releases or publications we issue), and outtake (for example,
the number of cuttings generated as a result, the potential audience reached,
the number publications requested). Details of the key indicators - with current
status and, where enough past data is available, forecasts - are in Appendix
two.




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4.1.1 The measures
Objective                        Measured by (research)          Frequency
Maintain awareness of rights     Annual Track                    Annually
(among individuals)
Raise awareness of               Annual Track                    Annually
obligations (among
organisations)
Encourage good practice          Separate campaign               At time of each campaign
(among organisations and         measures
individuals)
Maintain the reputation of the   Stakeholder perception          Every three years
ICO (among stakeholders)         research
Confidence in organisations’     Annual Track                    Annually
handling of information
(among individuals)
Increase customer                Customer Satisfaction           Alternate years –
satisfaction                     survey                          organisations, individuals
Raise awareness of the ICO       Annual Track                    Annually
as the enforcing authority
(among organisations)
Increase staff engagement        Staff survey                    Every two years
(see appendix 2 for key indicators and our latest performance figures)



4.2      Educating and influencing


4.2.1 Maintain awareness of rights (among individuals)
         Rationale: The Data Protection Act and the Freedom of Information
         Act both state that the Commissioner shall give the public whatever
         information that is appropriate on the operation of the Acts. We
         primarily promote and measure awareness of the rights rather than the
         Acts, as it is more useful for individuals to be aware of the rights the
         Acts bestow, rather than just to have heard of the Acts themselves. We
         need to maintain high awareness so individuals know they have rights
         and know how to take action when those rights are breached.
         Key indicator: Percentage of individuals who pick from lists the right to
         see information held about you, and the right to request information
         held by government and other public bodies (Annual Track).


4.2.2 Raise awareness of obligations (among organisations)
         Rationale: It is essential that those whose job it is to ensure personal
         information is properly looked after and that official information is
         accessible know their legal obligations. Our communications aim will
         now be to raise the awareness of the most important obligations among



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         organisations, rather than continue to raise their awareness of the
         rights (which is already very high). For data protection, we will focus on
         awareness of security and data minimisation (not collecting more than
         is necessary or keeping it for longer than is necessary). For freedom of
         information, we will focus on public authorities’ awareness that they
         must disclose information unless there is a legal reason not to, and
         secondarily on their obligation to help and advise people who ask for
         information.
         Key indicator: For data protection, the percentage of practitioners
         spontaneously aware of the obligations to keep data secure, to keep it
         for limited purposes and to keep it no longer than necessary. For
         freedom of information, the percentage of practitioners spontaneously
         aware of the obligations to disclose information unless there is a legal
         reason not to and to help and advise those who ask for information. We
         aim to improve on this. As these questions are new, there is not
         enough data to calculate a forecast.


4.2.3 Encourage good practice (among organisations and individuals)
         Rationale: Both the Data Protection Act and the Freedom of
         Information Act name promotion of good practice as a duty of the
         Commissioner. We need to meet - and anticipate - the information
         needs of our customers and supply ready-made information. By using
         management information to track and understand the areas of need,
         we will be able to create targeted campaigns and make
         communications improvements to help encourage good practice and,
         where possible, to help prevent calls. The ICO aims, in the future, to
         find a measure of good practice (possibly using the new audit model),
         which we will use to identify a stronger communications objective and
         accompanying measure.
         Key indicator: Indicators to be devised for the main projects or
         campaigns. Volumes of media coverage, web visits and publication
         distribution etc are monitored to gain an understanding of outtake.


4.2.4 Maintain the reputation of the ICO (among stakeholders)




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         Rationale: It is critical that the ICO has a good reputation, in order to
         engender trust and to influence effectively. It is also essential that the
         reputation matches the reality. As our profile grows, risk – as well as
         opportunity – grows with it. We need to protect the good stock we have
         built up, and changes – such as increased powers and a new
         Commissioner – will need careful management to ensure the ICO’s
         good reputation is maintained. We will continue to liaise with a wide
         range of stakeholders and to ensure our stakeholder strategy is
         effective. While all the objectives contribute to our overall reputation,
         key stakeholders will have particularly informed and influential opinions
         on the effectiveness of the ICO, so their views will be used as our key
         indicator.
         Key indicator: Stakeholders’ overall rating of the ICO as an
         organisation (Stakeholder perception research). Currently, 71% of key
         stakeholders rate our performance as excellent/very good. We aim to
         at least match this in the next survey, and to narrow the gap between
         the data protection and freedom of information stakeholder ratings,
         improving the ratings for freedom of information.


4.2.5 Confidence in organisations’ handling of information (among
         individuals)
         Rationale: The public’s confidence in the protection of their information
         rights is a useful indicator for us, and we must track it in order to
         understand the position of our audiences and to inform our
         communications work. However, it is subject to many factors, and the
         ICO’s performance is just one of them. This indicator, therefore, is less
         an indication of the ICO’s performance and more a key indicator of the
         public’s broad assessment of the state of freedom of information and
         data protection. Some concern is healthy – if confidence levels were
         very high, complacency would set in.
         Key indicator: Percentage of individuals who agree that organisations
         handle personal information in a fair and proper way, and percentage
         of individuals who agree that the information they want about
         government and other public authorities is available and accessible.
         The ICO would like to see the level of confidence in the fair and proper


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         handling of personal information stabilise (for example, at around 60%-
         65%). There is not enough past data available to calculate forecasts.


4.3      Resolving problems


4.3.1 Increase customer satisfaction
         Rationale: While the extent of customers’ satisfaction is often linked to
         the outcome of their case, we want all customers to find our complaints
         resolution service to be fair. Key drivers in overall satisfaction are
         helpfulness of reply, appropriate attention, being kept informed, time
         taken to respond, fair response, and clarity about what can be done.
         The key areas for improvement are the perceived authority of the ICO
         (ie our powers of redress), timelines, legal terminology and clarity of
         case status.
         Key indicator: Customer satisfaction index, which includes overall
         rating, quality of response, timeliness of response, overall impression,
         ease of contact and how well we kept customers informed (customer
         satisfaction survey, surveying organisations and individuals in alternate
         years). As this is a new survey, we do not have historical data to
         calculate a customer satisfaction forecast.


4.4      Enforcing


4.4.1 Raise awareness of the ICO as the enforcing authority (among
         organisations)
         Rationale: It is important that organisations know the authority to turn
         to, and who will take action if they don’t comply. Awareness of the ICO
         as the enforcing body for data protection and freedom of information is
         rising. We will aim to ensure that the ICO is at the forefront of the
         practitioner’s mind.
         Key indicator: Percentage of practitioners spontaneously aware of the
         ICO as the enforcing body of data protection and freedom of
         information. We aim to beat our forecast for data controllers and to
         match our forecast for freedom of information. We will also track



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         stakeholders’ perceptions of the ICO’s preparedness to enforce the
         law.


4.5      Developing and improving


4.5.1 Increase staff engagement
         Rationale: Employees are the ICO’s most important asset. ICO staff
         are knowledge workers, gaining satisfaction from interesting and
         stimulating work. Our staff survey gives us an insight into the views of
         the ICO’s workforce. In the past, staff satisfaction was our main
         measure, but - in line with other government bodies - we are now
         aiming to build on and develop staff engagement. Staff satisfaction is
         still important to us, but it is no longer the aim in itself. Being engaged
         is more than being satisfied or motivated. Engaged employees have a
         sense of personal attachment to their work and organisation that
         means they want to give their best to helping it succeed. Engaged
         employees tend to speak positively about their organisation and have
         an active desire to stay.
         Key indicator: We will track overall engagement as an indicator via an
         index of the five key areas of staff engagement for the ICO: job
         satisfaction, recommending the ICO as a place to work, being
         motivated, getting the best out of me and feeling valued. A good
         organisation would aim for an overall engagement index of 70-80, and
         we aim to improve ours to bring it nearer to this level.




5 How we will do it: our approach
5.1      Pick our position


The ICO’s positioning since 2005 has been “The UK’s credible, robust and
helpful authority on information rights”. While we continue to strive to be all
these things, we feel these characteristics have been built into our corporate
approach and embedded in strategies, policies and procedures. It is now time
to move to a more aspirational positioning over the next three years: “The ICO


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is the UK’s independent, influential and practical authority on information
rights and responsibilities, making a difference to people”. Changes on the
horizon – such as a new Commissioner and increased powers – will need to
be prepared for carefully, with consideration given to the implications they
have for our positioning. As an articulation of our new positioning, our
corporate identity will serve us over the next three years without major
changes. We will need to adapt to keep pace with technology, considering the
potential of new communications channels such as blogs, wap and wider
online presence. More pictures (and more realistic, diverse pictures) of people
will be included, we will improve our recruitment materials and strengthen the
branding for internal communications materials.


5.2      Engage staff


The internal communications challenge is harder now, as we are moving
towards behaviour and culture change. While communications can support
and articulate engagement work, real success will lie in leadership and
management approach. The Communications and External Relations
department will work closely with other departments to help develop and
improve engagement among staff. ICO senior management will actively seek
more ways of involving staff, getting their views and feeding back. We will aim
to make Executive Team members more accessible and to raise their profile.
The Communications and External Relations department will support and
coordinate much of this new work, with increased input from senior staff within
the department, reallocating resources within the department to make this
possible. We will work closely with the HR department to develop the ICO’s
employer branding and improve recruitment materials. The ICO will measure
the five key areas of staff engagement for the ICO: job satisfaction,
recommending the ICO as a place to work, being motivated, getting the best
out of me and feeling valued. We will concentrate on the strategic
improvement areas of line management, wellbeing and development and
senior management, which for staff are areas of high importance but lower
performance.




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Communications play a significant role in the way staff feel about the ICO.
The latest survey shows that 72% feel informed about the organisation (well
above the public sector norm). The information is also deemed to be credible
(65% agree compared to the public sector norm of 57%). There is a close
match on the channels staff say they would prefer to use for information
compared to how they actually receive it. The real challenge now lies with
management skills and style. Demand for more face-to-face communications
from line managers, via team briefings and from senior management, outstrips
current levels of supply. Our emphasis will be on helping managers to
understand their role and improve their skills in internal communications and
staff engagement.


5.3      Get closer to our customers


Among the key drivers of satisfaction for our customers are the helpfulness
and appropriateness of the reply, being clear about what we can do and being
kept informed. Among stakeholders (ie organisations or groups), the key
drivers in their assessment of the ICO are quality of advice and information,
and professionalism (a broad term including being open, replying promptly,
giving high quality responses, being honest, pragmatic, helpful and accurate).
Our customer service and complaints handling teams contribute most to these
key drivers. Communications and External Relations can support this with
well-targeted and clearly written communications, particularly the website and
e-newsletter, and continuing our plain language training. Stakeholders’ ratings
for freedom of information are lower in most cases than for data protection,
and the ICO will address concerns such as the need for revised freedom of
information guidance, explaining our slow responses, closer stakeholder
liaison and more consistency in advice.


We need continue to find ways of explaining to potential customers what the
ICO actually does and our role in helping to resolve everyday information
rights problems. Keeping intermediaries up to date is critical to this, as is
achieving media coverage showing real life experiences where we have
intervened and made a difference. We need to target consumer, youth, ethnic
and specialist media with these stories to ensure we are reaching diverse


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audiences wherever possible. We will gain greater understanding of how data
protection and freedom of information is managed in organisations.


We need to boost confidence among organisations that they can do data
protection well – providing clear guidance, responding quickly to hot topics
and busting myths will help. Nearly half our data protection cases require
advice as the outcome: more work is required to analyse the management
information from both data protection and freedom of information caseloads.
Working closely with frontline customer service staff, we can identify the
preventable referrals and frequently asked questions, and provide the
information where our customers will see it. In addition, we need to present
our guidance in a more user-friendly way, driving traffic away from our phones
and towards our website, creating easy routes to find it on our website, for
instance by providing sector- and topic-specific user journeys, and frequently
refreshing our FAQs. Currently, 73% of our complainants rate the site
excellent, very good or good. The new notification fees and increased powers
of audit offer tremendous opportunities for the ICO to remind data controllers
about their role as data protectors.


Nearly a quarter of freedom of information complaints are rejected as
ineligible: we will do further analysis to find out which category of ineligible
they fall into and to improve our communications to help people to make
complaints in the right way. We need to help central and local government to
respond to freedom of information requests properly (together they account
for the majority of our freedom of information complaints, with health and
police and criminal justice the next largest groups).


5.4      Manage the messages


Research by the Henley Centre cites privacy and openness as one of
society’s six paradoxes. There is a trend showing increasing desire for
organisational transparency; the countertrend is increasing desire for personal
privacy. The ICO is dealing with top social issues: we must be clear what we
are saying and where we are taking them. We will sharpen our messages to
support our strategies and policy positions, developing long-term overarching


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messages, tailored messages for differing audiences and convincing,
pertinent evidence to give weight to our arguments. We will also aim to give
clearer messages to manage customers’ expectations of what we can do for
them, preventing unnecessary referrals to the ICO.


5.5      Create an expectation


We will aim to convince people that good information rights practice is a
matter of social responsibility as well as an essential part of good
organisational management. We need to create an expectation in society,
where we illustrate good practice by organisations. The themes outlined in the
Data Protection Strategy will help to communicate what the ICO sees as good
practice and a desirable norm. The high profile of recent data losses has
drawn attention to the importance of safeguarding people’s personal
information, but it has also damaged public confidence that personal
information is well protected. The nature of freedom of information polarises
views, with decisions often pleasing one party and disappointing another.
While communicating freedom of information decisions remains a core part of
our role, we also need to promote transparency as the desirable norm for a
public body: promotion of the ICO’s new Publication Scheme initiative will help
with this. We will emphasise that poor information rights practice poses a risk
to an organisation’s reputation, and we will demonstrate that good practice
can enhance reputation. We will also encourage consumers to become more
vocal in calling for their information rights to be respected, and explore the
provision of educational materials for schools and young people.


5.6      Embrace the web


Recognising that only the most determined customers will come to our
website, we will expand our web presence to ensure we put information where
our prospective customers will see it. We will continue to monitor information
rights issues across the web, and respond quickly. We will also explore
opportunities to increase our online communications activities and develop
new channels accordingly.



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We must develop our web service and presence at a pace that matches the
public’s expectations and meets their needs. A successful website makes
things easier for people and helps them to do things, and our approach will be
to improve functionality and to present information from the user’s perspective
rather than our own. We will offer a more responsive, newsy website, and
work closely with our customer service teams to reflect and anticipate
customer needs, with the aim of reducing calls and preventing referrals by
providing the information on our website. We will create more user journeys
for sectors, and to reflect individuals’ needs and experiences, making it easier
for people to find the advice they need quickly. We will increase the resource
we put into web content work, reallocating resources within the department to
make this possible.




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6 Messages
(Please note that these are indicative, stock messages, and are likely to change. Actual
messages will be tailored and agreed to suit specific situations, audiences and media).


6.1      ICO


6.1.1 We protect your rights to see official public information and to see the
         personal information organisations hold about you.
6.1.2 The Information Commissioner’s Office promotes public access to
         official information and protects your personal information.
6.1.3 The ICO is the UK’s independent, influential and practical authority on
         information rights and responsibilities, making a difference to people.
6.1.4 The ICO’s vision is a society where information rights and
         responsibilities are respected by all:
         •        Organisations inspire trust by collecting and using personal
                  information responsibly, securely and fairly;
         •        People understand how their personal information is used, are
                  aware of their rights and are confident in using them;
         and
              •    Public authorities are open and transparent, providing people with
                   access to official information as a matter of course;
              •    People are aware of their rights of access to official information
                   and are confident in using them.
6.1.5 There are four main focuses to the work of the ICO: educating and
         influencing, resolving problems, enforcing, developing and improving.
6.1.6 We will help you where we can, and if we can’t help, we’ll let you know
         as soon as we are able to, and explain why.
6.1.7 The ICO aims to achieve world-class performance through a diverse
         and motivated workforce, with a focus on helping everyone to get the
         best out of themselves and each other.




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6.2      Data protection


6.2.1 Strategic approach
 •        We protect people, not just information.
 •        We focus on situations where there is likelihood of serious harm.
 •        We equip individuals to help them make their own decisions.
 •        We aim to influence the environment in which people’s personal
          information is handled.
 •        We aim to simplify data protection and make it easier to understand.
 •        We take a practical approach, making it easier for organisations to
          handle information well and being tough on those who don’t.


6.2.2 Illegal trade in personal information
Overarching message            Stamp out this illegal trade.
Message for individuals        We’re onto the criminals who are illegally buying and selling
                               personal information.
Message for organisations      Train your staff.
Example killer fact            We have successfully prosecuted x organisations


6.2.3 Surveillance society
Overarching message            Protecting privacy is essential in a world of increasing
                               surveillance.
Message for individuals        Data protection gives you important rights and some control
                               over the information held about you.
Message for organisations      Design privacy into your systems and processes.
                               Privacy by design
Example killer fact            The average adult appears on x databases.
                               There are x CCTV cameras in the UK.


 6.2.4 Security of personal information
Overarching message            Security of personal information is of fundamental
                               importance to privacy.
Message for individuals        Demand security for your personal information.
                               Take steps to keep your information secure.
Message for organisations      Poor information security damages your customers and your
                               business.
Example killer fact            X million victims of identity fraud each year.
                               X records lost last year.




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 6.2.5 Information sharing
Overarching message               Information sharing brings benefits, but it also creates risks.
Message for individuals           Data protection gives you important rights over the
                                  information held about you – use them.
Message for organisations         Use the ICO’s code of practice to get information sharing
                                  right.
Example killer fact               The public’s confidence that organisations look after their
                                  personal information adequately is xx




6.2.6 Law enforcement and personal information
Overarching message               We’re making sure all the personal information collected by
                                  law enforcement agencies really is needed to prevent crime
Message for individuals           Do you know what information is held about you?
Message for organisations         Law enforcers are not above the law.
Example killer fact               More CCTV cameras per head than anywhere else in the
                                  world.
                                  Largest DNA database in the world.
                                  The police hold information on you for 99 years.


6.2.7 Supervision of data protection
Overarching message               Data crosses borders and so must data protection
Message for individuals           We’re working with others to safeguard your personal
                                  information internationally
Message for organisations         Good data protection lifts the barriers to international data
                                  exchange
Example killer fact               There are no barriers to international data transfer within the
                                  EU


6.3      Freedom of information
(Please note this is draft, pending the forthcoming freedom of information strategy)


6.3.1 Strategic approach
 •        We believe openness and transparency is an essential component of
         good government.
 •        We expect public authorities to be open and transparent as a matter of
         course, routinely publishing information in accordance with their
         publication schemes, and replying to freedom of information requests
         promptly.
 •        We take a practical approach, encouraging organisations to handle
         information well and being tough on those who don’t.
 •        We expect users to be responsible - vexatious behaviour is
         unacceptable.




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 •        We are robust in our case handling, deciding each case on its merits,
         aiming for informal resolution where possible, and providing clear
         decision notices which explain our reasoning.


6.3.2 Making openness the norm
Overarching message           Openness should be the norm
Message for staff             Lead by example
Message for individuals       You have a right to public information
Message for freedom of        Openness is the presumption – you need a legal reason not
information officers          to disclose.
Message for stakeholders      Transparency and openness provide real reputation
                              benefits.
                              Public money is being spent – the public have a right to
                              know
Example killer fact           X amount of information is already available from public
                              authorities.
                              Openness is one of the seven principles of public life
                              (Committee on Standards in Public Life).
                              72% of people believe that being able to access information
                              held by public authorities increases your trust in them


6.3.3 Being an effective complaints resolution authority
Overarching message           We resolve freedom of information disputes firmly and fairly.
                              It’s often complex and each case is decided on its merits.
Message for staff             Be clear and consistent – use the ICO’s guidance and
                              procedures.
Message for complainants      We are reducing the time it takes to deal with complaints
                              You will know what will happen with your complaint and
                              when it will happen.
Message for freedom of        If you refuse to disclose information, explain why.
information officers
Message for stakeholders      Be more open with the ICO – we are here to help you and
                              the public, to make freedom of information work.
Example killer fact           Nearly a quarter of the complaints we receive are ineligible
                              – check you get yours right first time.
                              The outcome of our complaints last year was 30% upheld,
                              25% not upheld, 45% varied.
                              In three-quarters of cases, we uphold the case in full or part.


6.3.4 Persistent poor performance will lead to enforcement action
Overarching message           Persistent poor performance will lead to enforcement action
Message for individuals       You can be confident we will use our enforcement powers to
                              protection your rights.
Message for freedom of        You won’t get away with it.
information officers          We can help you comply through informal resolution where
                              possible, and with enforcement action where necessary.
Message for stakeholders      Poor performance won’t be tolerated.
                              Poor performance damages reputation.
Example killer fact           X enforcement actions in the last year.
                              You will be used as an example




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6.3.5 Personal information about a public role should normally be
         disclosed
Overarching message         Public figures should expect to be transparent
Message for staff           Think office-wide – we are responsible for both data
                            protection and freedom of information.
Message for individuals     Freedom of information gives you the right to see official
                            information held by public bodies. Data protection gives you
                            the right to see information held about you.
Message for freedom of      The public have a right to know where public money is being
information officers        spent.
Message for stakeholders    Things have changed since the Freedom of Information Act.
Example killer fact         X% of freedom of information complaints have a data
                            protection element
                            86% of people are aware of their right to know


6.3.6 Openness and good government are compatible
Overarching message         Openness and good government are compatible
Message for individuals     Lots of information is readily available – you may not need
                            to make a special request
Message for freedom of      Giving information improves relations with your customers
information officers
Message for stakeholders    Openness is one of the seven principles of public life
                            (Committee on Standards in Public Life).
Example killer fact         X amount of information is already available from public
                            authorities.
                            72% of people believe that being able to access information
                            held by public authorities increases your trust in them


6.3.7 Good record keeping is essential for freedom of information
compliance
Overarching message         Good information management is essential for freedom of
                            information
Message for individuals     Well-defined and specific requests get you information more
                            quickly
Message for organisations   Invest in records management – it establishes consistency
                            and efficiency, saving time and money in the long run
Example killer fact         X% of complaints were upheld because records
                            management was poor




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7 Audiences and how we reach
them
7.1      Categories


The ICO’s audiences are potentially numerous, as data protection and
freedom of information can affect everyone in the UK. In practice, our
audiences fall into four broad categories:


•         ICO staff, potential staff and suppliers.
•         Individuals (ie people with information rights; also called consumers,
          customers, individuals, the public or citizens)
•         Practitioners (ie people whose role, or part of whose role, is to ensure
          data protection and freedom of information laws are observed; also
          called data protection officers and freedom of information officers)
•         Stakeholders (organisations or groups affected by, or having an
          interest in, our operations, or able to influence other groups; this
          includes intermediary bodies and our international counterparts).


Of course, these groups themselves will be broken down into sub-categories
for specific purposes such as campaigns or targeted messages. Notable
subgroups include individuals and organisations who use our helpline, advice
and complaints services; organisations who notify with us under the Data
Protection Act or who are subject to the Freedom of Information Act; and our
website users. In addition, within the individuals category, we are aiming to
reach diverse audiences, including young people and people in lower socio-
economic groups, who are less likely to be aware of or to exercise their
information rights. Our stakeholder category can be further broken down, for
example by sector, such as specific trades or professions (see our separate
stakeholder strategy).




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7.2      What customers want


Organisations cite the ICO as their main source of advice on the Acts, and
there is a growing demand for web-based materials. Individuals say they
would turn first to referral bodies such as the Citizens Advice Bureau, and,
increasingly, to the internet. We acknowledge that individuals still want printed
documents to be available. As people tend to hear about the Acts through
work and the media, continuing to raise awareness through targeted news
stories is important.


7.3      Communication channels


This is not an exhaustive list, but serves to indicate the main methods we use
to get information and messages to our audiences. We seek regular feedback
from our audiences, via our market research programme, to ensure we
understand their preferences and to get specific comments on, for example,
our website, services, events and publications.


              Audience                     Key channels to reach them

              Staff, potential staff and   In-house magazine (Informer)
              suppliers                    Intranet (ICON)
                                           Publications
                                           Team meetings
                                           Briefing sessions (ICONNECT)
                                           Managers’ briefs
                                           All staff briefings
                                           Team meetings
                                           Key messages from committees/projects
                                           Notice boards/posters etc
                                           Workshops, consultation sessions etc
                                           Engagement sessions with Executive Team
                                           Corporate calendar

              Individuals                  Media
                                           Publications
                                           Website
                                           Online
                                           Advertising

              Practitioners                Media
                                           Guidance/publications/training DVDs
                                           Website
                                           Online
                                           E-newsletter
                                           E-alerts
                                           Speaking engagements
                                           ICO events/conferences


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                                          Exhibitions/conferences
                                          Meetings
                                          Direct mail
                                          Advertising

              Stakeholder organisations   Media
                                          Publications
                                          E-newsletter
                                          E-alerts
                                          Speaking engagements
                                          ICO events/conferences
                                          Meetings
                                          Events/conferences
                                          Website
                                          Direct mail
                                          Proactive FOI disclosures



7.4      Priority communications channels


Online communications and media relations continue to be our priority
communication channels. Both are mass, instant and influential, and we
cannot choose whether to have a media or web presence, only whether to
manage or influence them actively or not. For the media, we will continue to
stimulate debate in the broadsheets and in the news, to reach organisations
via the trade press, and to reach individuals through the consumer and
regional media. We will continue to tell stories that relate to real life, both
online and in the print and broadcast media. We will develop our web
presence to go beyond our own site, with the aim of ensuring good quality
information is in the places people will look for it. The emphasis for our site will
be on ease of access, search and navigation, a more dynamic and newsy
homepage, and to provide information through relevant user journeys. The e-
newsletter has been well-received and we will continue to solicit and act on
feedback from our readers and to expand our list of subscribers.
We have had excellent feedback on our training DVD for data protection and
will produce similar DVDs on other subjects. We are encouraged by the
positive feedback we have had about our new publications and e-newsletter.
Print publications are likely to remain with us for at least another 20 years, and
we will strive to produce both print and online information. We will continue to
streamline our print materials and to plug gaps in available information.




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7.5      Areas for continued development


Internal communications continues to be a priority, with the emphasis on two-
way discussion and on staff engagement. Now we have developed quality
internal communications tools, we will move the focus to developing
communications skills (as a required competency), on communications as
integral to organisational culture and as a management role. The aim is to
increase trust and improve inter-departmental communications.


The emphasis stays on coordinating stakeholder relations, with the aim of
working efficiently and effectively, and prioritising our time. We will refresh our
stakeholder strategy, re-organising it to show clearly how stakeholder
relations work supports the key themes in the Data Protection Strategy, and
the forthcoming Freedom of Information Strategy.




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8 Creative treatment
8.1      What customers want


Our stakeholders tell us that they want good quality advice, guidance and
information and they want it to be clear, authoritative and user-friendly. They
would also prefer it to be less formal in style, and made recognisably relevant
to them, their jobs and their sectors. Individuals and organisations are
increasingly demanding web-based materials, easy to find on the internet.


8.2      Branding


Branding and creative work must support our new positioning: “The ICO is the
UK’s independent, influential and practical authority on information rights and
responsibilities, making a difference to people”. The ICO’s corporate identity
will apply, and be developed to ensure it is fresh and applicable over the next
few years. In particular, we want to strengthen branding for recruitment
materials, internal communications and any new electronic channels we may
use. The lead logo will be the ICO logo; distinct sub-brands will not be
created. The mission statement (“Promoting public access to official
information and protecting your personal information”) will appear on all
relevant materials (with the logo). Visual material will be clear, authoritative
and forward looking.


8.3      Style


Our written style and language will continue to be suitable for the medium and
the audience, with the emphasis on plain language. Having run successful
pilots, we now have tailored plain English training for staff. Materials will be
written in accordance with our publication categories, which provide for three
levels of need: introductory, practical application and detailed or specialist.
Our Style Guide will be adhered to in all published materials; we aim for a
style that is decisive, helpful and clear.



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8.4      Diversity
We will make sure our materials are accessible (see section 2.6). Our
materials will reflect society and will not exclude specific groups: they will have
inclusive style and imagery.




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9 Distribution
9.1      Website


We continue to develop our presence on search engines, and to monitor
references to us on other web sites. We have reciprocal links with appropriate
organisations and contribute content to other relevant sites such as
www.directgov.gov.uk and www.businesslink.gov.uk. We regularly monitor
sites with user-generated content. We will to do more to increase our
presence and get our messages on relevant websites over the next three
years.


9.2      Media


We continue to broaden our media circulation to be inclusive of diverse
audiences, and to extend our presence on the web and in consumer and
popular media. We are striving to reach hard to reach audiences such as
C2DEs and young people, via consumer media, with human interest stories.


9.3      Speaking engagements and events


We continue to coordinate and prioritise speaking engagements, matching
them with our corporate aims. We are improving our evaluation, so best use is
made of staff time. Demand outstrips our ability to supply speakers and we
are working to prioritise these requests.



9.4      Publications


We promote our publications via media relations, especially in the trade and
consumer media, on our website, our e-newsletter, and with some advertising.
We also circulate our most popular leaflets via the Citizens Advice Bureau and
other key intermediaries. Our fulfilment contract gives us stock listings and




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early warnings of reprints needed, and provides information on the most
popular leaflets.


9.5      Campaigns


Advertising slots will be bought using available research on our target
markets. Free-to-air broadcast slots are sought.


9.6      Direct


We will distribute our publications, e-newsletter, training materials and other
information of interest direct to our stakeholders. We will improve and make
more use of our notifications database to keep in direct contact with data
controllers and freedom of information officers.




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10 Budget and resource
10.1 Priorities


A high proportion of our budget goes on fixed costs (the basics needed to run
a press office and a website). Evaluation of communications work means we
are in a stronger position to know where to spend our money most effectively.
The top four items are media, online, research and print and design. Media
and online work continue to be our top priorities and will take the largest
proportions of budget; the spend here will not diminish. The more successful
we are at generating media coverage, the more it costs in terms of monitoring
and demand. We can also be sure that online investment will grow. We now
have a new website, but we must move fast to keep pace with developments
and customer expectations. Design and print expenditure has now started to
reduce as we streamline our publications and move to more web-based
materials. Evaluation should typically cost around 10% of budget; however,
our research also contributes to the wider understanding of attitudes to and
awareness of information rights: we therefore intend that spend on research is
around 15%-19% of budget.


10.2 Small but significant


Internal communications and distribution are relatively low proportions of the
budget, though both are vital investments. Feedback from ICO staff shows we
need to increase Communications and External relations time spent on
internal communications. This is to start new initiatives, manage change
communications, advise managers, set up templates and demonstrate what
can be done. We continue to review our expenditure on consultancy.
Stakeholder relations work does not take a lot of Communications and
External Relations budget but is time-intensive.




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10.3 Forecast


Expenditure has varied from £700k in 2004, to £1.5m in 2009, depending on
budget availability, ICO communications needs, strategy and staffing. The
strategic emphasis on influencing required by the Corporate Plan, coupled
with the heightened public interest in both data protection and freedom of
information issues, means that communications and external relations spend
must remain one of the higher investments of the ICO.


The pressing need is to invest money and time in online and internal
communications work to bring us up to modern expectations. We aim to do
this by reallocating resources within the team. Spend on media relations will
remain a high fixed cost, and a priority: we are constantly seeking ways to
keep costs down. We can make some savings (by not reinstating paid-for
advertising, except on a very modest scale, and reducing print and research
work).


We also need to catch up on our freedom of information communications,
following reinstatement of the communications budget which was cut to
provide complaint handling staff. In particular, we need to promote good
practice and offer clearer guidance, with the aim of reducing the number of
freedom of information complaints to the ICO.


We will bring forward projects suitable for quick implementation should we
exceed our data protection fee income projections, and will continue to
reallocate or reuse efficiency savings or underspends. In addition, potential
new powers for data protection will have an impact on ICO communications,
and this has yet to be quantified.




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11 Review and evaluation
11.1     Progress against the actions in this strategy will be reviewed quarterly,
         as part of the ICO’s business plan reporting methods.


11.2     Effectiveness of communications will be reviewed quarterly, as part of
         the ICO’s evaluation report on communications, submitted to the
         Management Board. This will include an annual round up in the final
         quarter of the year. In addition, market research reports will give rise to
         detailed assessments of success against objectives.


11.3     Strategic direction will be reviewed annually, to ensure the strategy is in
         line with the Corporate Plan and other related ICO documents. In
         addition, market research reports will inform a review of the strategy
         and of each objective.




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Appendix 1: Sources
•         CIPD Annual Survey Report 2008
•         Data Protection Act Part VI, 51 (1,2)
•         Effective Communication: A Leading Indicator of Financial
          Performance - 2005/2006 Communication ROI Study – Watson Wyatt
•         Feedback from consultation on Data Protection Strategy, November
          2007
•         Freedom of Information Act Part III, 47 (1,2)
•         Freedom of Information one/two/three years’ on, Continental Research
          for ICO, 2006, 2007, 2008.
•         Government Communications Network website www.comms.gov.uk
•         ICO Annual Report 2006/07, 2007/08
•         ICO Annual Track research, Quaestor 2004, SMSR 2005, 2006, 2007,
          2008
•         ICO Corporate Plan 2008-20011, 2009-12
•         ICO Customer satisfaction research (data protection), Jigsaw, 2005,
          2006
•         ICO Customer satisfaction research (freedom of information), Jigsaw,
          2006
•         ICO Data Protection Strategy
•         ICO Disability Equality Scheme
•         ICO HR Strategy
•         ICO management information 2006/07, 2007/08
•         ICO Northern Ireland Disability Action Plan
•         ICO Northern Ireland Equality Scheme
•         ICO Notifications payment consultation, SMSR, March 2008
•         ICO publications feedback, Cragg Ross Dawson, 2007
•         ICO staff survey, IPSOS MORI, 2005, 2007, 2009
•         ICO BHD survey, IPSOS MORI, 2009
•         ICO stakeholder perception study, Jigsaw, 2008
•         ICO (website) usability review, CAD interactive, March 2006
•         ICO website statistics



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•         Talking to me? Connecting with Citizens, Henley Centre Headlight
          Vision research for the Cabinet Office, 2006
•         Watson Wyatt 2007/2008 Communication ROI study “Secrets of top
          performers: how companies with highly effective employee
          communication differentiate themselves”.
•         Which messages spur citizens to protect the environment? The secret
          impact of social norms, Professor Robert Cialidini, RSA 2007,
          http://www.rsa.org.uk/acrobat/cialdini_250107.pdf




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Appendix 2: Key indicators
Updated to include new Annual Track figures; graphs by Planning Express.
Forecasts are mathematical calculations based on past data.

Educating and influencing
Communications objective: maintain awareness of rights (among individuals)

Indicator 1       How aware are individuals of their data protection rights? (prompted)
                                    2009                         2008                        2007                        2006                        2005                         2004
Actual                                                           86%                         90%                         82%                         76%                          74%
Forecast                             88%                         93%                         85%                         76%                            -                            -
Method            Prompted question: “Which of the following rights do you think you have with regards to your personal details held by organisations?”; Sample 1000 interviews. Quotas
                  set on age, sex, region and social grade to ensure a nationally representative sample. Percentage who pick “The right to see information”. Measured by Annual Tracking
                  survey (SMSR). Forecasts calculated by SMSR using past data.




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        For          How aware are individuals of their data protection rights? (spontaneous)
        comparison                       2009                         2008                        2007                      2006                          2005                        2004
        Actual                                                        51%                          42%                      45%                            39%                         39%
        Method       Spontaneous question: “Everybody has personal details including your name, your address, your bank account details or even your credit rating information. What rights
                     do you think you have to access personal details held about you by organisations?” Percentage who say “The right to see information”.




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Indicator 2   How aware are individuals of their freedom of information rights? (prompted)
                                 2009                        2008                         2007                        2006                         2005                        2004
Actual                                                       75%                          86%                         73%                          73%                            -
Forecast                         78%                         81%                             -                           -                            -                           -
Method        Prompted question: “Which of the following rights do you think you have with regards to accessing information held by the government and other public authorities?”.
              Sample 1000 interviews. Quotas set on age, sex, region and social grade to ensure a nationally representative sample. Percentage who pick “The right to request
              information held by the government and other public authorities”. Measured by Annual Tracking survey (SMSR). Forecasts calculated by SMSR using past data.




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        For          How aware are individuals of their freedom of information rights? (spontaneous)
        comparison                         2009                       2008                          2007                      2006                         2005                        2004
        Actual                                                         31%                          28%                       25%                           23%                            -
        Method       Spontaneous question. “What rights do you think you have to access information held by the government and other public authorities? Sample 1000 interviews. Quotas
                     set on age, sex, region and social grade to ensure a nationally representative sample. Percentage who say “The right to request information held by the government and
                     other public authorities”. Measured by Annual Tracking survey (SMSR).




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Communications objective: raise awareness of obligations (among organisations)

Indicator 3               How aware are practitioners of the most
                          important data protection principles?
                          (spontaneous)
                                           2009                       2008                       2007
Secure                                                                55%                        69%
Limited                                                               24%                        40%
Not kept longer                                                       25%                        39%
than necessary
Method                    Spontaneous question: “What are the principles you are aware of that
                          organisations have to comply with when processing personal information?”
                          asked of 400 public authorities and 400 businesses. Measured by Annual
                          Tracking survey (SMSR).


              For comparison
              Awareness of all eight principles          2008         2007
              (spontaneous)                               9%          22%


              For comparison        How aware are practitioners of the
                                    most important data protection
                                    principles? (prompted)
                                          2009         2008          2007
              Secure                                  100%          100%
              Limited                                  96%           98%
              Not kept longer                          95%           97%
              than necessary




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Indicator 4               How aware are public authorities of the most
                          important FOI obligations? (spontaneous)
                                              2009                     2008                        2007
Must disclose                                                          30%                         52%
Help/advise                                                            32%                         50%
Method                    Spontaneous question: “What legal obligations are you aware of that apply to
                          public authorities under the FOIA?” asked of 400 public authorities. Measured
                          by Annual Tracking survey (SMSR).


              Aware of all four obligations             2008              2007
                                                        11%               30%

              For comparison        How aware are practitioners of the most
                                    important freedom of information
                                    objectives? (prompted)
                                           2009          2008           2007
              Must disclose                              98%            97%
              Help/advise                                97%            99%


Communications objective: encourage good practice

This is measured by keeping an overview of activity and outcome, and by measuring the effect of specific campaigns.
2007/08 figures:
•         Over 2380 media articles proactively generated (over 50% more than 2006/07), 95% positive, with an audience reach of 764
          million (more than double 2006/07 figures)
•         Over 240k publications issued (now declining after a sharp rise in 2006/07)
•         Around 1.6 million web visits a year, from around 1 million visitors; 82% satisfaction score.
•         Around 3780 e-newsletter subscribers.




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Communications objective: maintain the reputation of the ICO (among stakeholders)

Indicator 5         What are stakeholders’ overall perceptions of the ICO?
                                                       2011                                        2008
Actual                                                                          71% excellent/very good
Method              “Overall, taking everything into account in terms of the advice they give you, your dealings
                    with them and the quality of your relationship, how would you rate the overall performance
                    of the Information Commissioner’s Office?” asked of key stakeholders (universe 50).
                    Scale: excellent, very good, good, fair and poor. Measured by stakeholder perception
                    survey (Jigsaw Research)


Communications objective: confidence in organisations’ handling of information (among individuals)

Indicator 6         Do people feel that organisations handle the details they collect about them in a fair and proper way?
                                       2009                          2008                         2007                         2006                         2005                         2004
Actual                                                               47%                          50%                          47%                          40%                          42%
Forecast                                49%                             -                            -                            -                            -                            -
Method              “I am now going to read out a list of statements and this time I would like you to tell me the extent to which you agree or disagree which each of the following statements”
                    Sample 1000 interviews. Quotas set on age, sex, region and social grade to ensure a nationally representative sample. Percentage who agree with the following
                    statement “Organisations handle the details they collect about you in a fair and proper way.” Agree/disagree on a scale: stating agree or strongly disagree. NB, in
                    previous years the question was a numbered scale from 1 – 5. Annual Tracking survey (SMSR).


 100%
  90%
  80%
  70%
  60%
  50%
  40%
  30%
  20%
  10%
   0%
          2004 2005 2006 2007 2008




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Indicator 7                 Do people feel that the information they want about
                            government and other public authorities is available and
                            accessible?
                                                                         2009                                                   2008
Actual                                                                                                                          50%
Method                      “I am now going to read out a list of statements and this time I would like you to tell me the extent to
                            which you agree or disagree which each of the following statements” Sample 1000 interviews.
                            Quotas set on age, sex, region and social grade to ensure a nationally representative sample.
                            Percentage who agree with the following statement “Information you want about government and
                            other public authorities is available and accessible”. Agree/disagree on a scale: stating agree or
                            strongly disagree. Annual Tracking survey (SMSR).




Resolving problems
Communications objective: increase customer satisfaction

Indicator 8                 Customer satisfaction index
                                                2010                          2009
Individuals                                                                     48
Organisations                                                                    -
Method                      Index is scored out of 100 and comprises:
                            Overall rating (30%)
                            Quality of response (25%)
                            Timeliness of response (25%)
                            Overall impression (10%)
                            Ease of contact (5%)
                            How well kept informed (5%)
                            2009 survey: 420 telephone interviews (263 DP, 102
                            FOI, 55 Enquiries), closed cases in last 3-6 months.

              For               How do individuals rate the ICO’s customer service? (old survey results)
              comparison                             2006                     2005                         2004
              Actual            Data protection            Data protection                                     -
                                complainants: 28%          complainants: 29% poor;
                                poor; 36% excellent/v      26% excellent/v good
                                good.
                                FOI complainants: 7 out
                                of 26: poor; 12 out of 26:
                                excellent/v good
              Please note       These older customer satisfaction surveys were conducted differently so direct
                                comparisons cannot be made with the 2009 survey.




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              For               How do organisations rate the ICO’s customer service? (old survey
              comparison        results)
                                                   2006                        2005                        2004
              Actual            Data protection: 15%       Data controllers: 13%                               -
                                poor; 32% excellent/v      poor; 47% excellent/v
                                good.                      good
                                FOI: 12% poor; 40%
                                excellent/v good
              Please note       These older customer satisfaction surveys were conducted differently so direct
                                comparisons cannot be made with the 2009 survey.



Enforcing
Communications objective: raise awareness of the ICO as the enforcing authority (among organisations)
Indicator 9                 How much are data controllers aware of the ICO as the enforcing authority of the Data Protection Act?
                            (spontaneous)
                                               2009                        2008                         2007                        2006                         2005                        2004
Actual                                                                     65%                          69%                         44%                          52%                         48%
Forecast                                       67%                         56%                          48%                            -                            -                           -

Method                      Spontaneous question: “Can you tell me of any organisations you are aware of that are responsible for enforcing the Data Protection Act?; asked of 400 public
                            authorities and 400 businesses; percentage who reply Information Commissioner or Information Commissioner’s Office. Measured by Annual Tracking survey (SMSR).
                            Forecasts calculated by SMSR using past data.


              For             Recall of other authorities (spontaneous)
              comparison                         2009                     2008                            2007                         2006                         2005                        2004
              Actual                                     Govt 9%; DP Agency          4% believe it is the        4% believe it is the Data    9% believe it is the Data   7% believe it is the Data
                                                         4%; DP Commissioner         government; 3% believe      Protection Agency;           Protection Agency;          Protection Registrar
                                                         2%; DCA 1%.                 it is the Data Protection   2% believe it is the Data    5% believe it is the Data   (Commissioner).
                                                                                     Registrar                   Protection Registrar         Protection Registrar
                                                                                     (Commissioner).             (Commissioner).              (Commissioner)
              Method          Spontaneous question: “Can you tell me of any organisations you are aware of that are responsible for enforcing the Data Protection Act?; asked of 400 public
                              authorities and 400 businesses; percentage who reply Information Commissioner or Information Commissioner’s Office. Measured by Annual Tracking survey
                              (SMSR).


Indicator 10                How much are public authorities aware of the ICO as the enforcing
                            authority of the Freedom of Information Act? (spontaneous)
                                               2009                        2008                         2007                        2006
Actual                                                                     80%                          84%                         70%
Forecast                                       82%                         84%                             -                           -
Method                      Spontaneous question: “Can you tell me of any organisations you are aware of that are responsible for
                            enforcing the Data Protection Act?; asked of 400 public authorities and 400 businesses; percentage who reply



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                           Information Commissioner or Information Commissioner’s Office Measured by Annual Tracking survey
                           (SMSR). Forecasts calculated by SMSR using past data.

              For           Recall of other authorities (spontaneous)
              comparison                         2009                        2008                               2007                         2006
              Actual                                      Govt 6%; SICO 5%; MOJ         5% believe it is the office  4% believe it is the office
                                                          3%; DCA 2%; DPA 1%.           of the Scottish Information  of the Scottish Information
                                                                                        Commissioner; 4%             Commissioner;
                                                                                        believe it is the            4% believed it is the
                                                                                        government.                  Department of
                                                                                                                     Constitutional Affairs;
                                                                                                                     2% believe it is the Data
                                                                                                                     Protection agency.
              Method        Spontaneous question: “Can you tell me of any organisations you are aware of that are responsible for enforcing the
                            Data Protection Act?; asked of 400 public authorities and 400 businesses; percentage who reply Information
                            Commissioner or Information Commissioner’s Office. Measured by Annual Tracking survey (SMSR).




              For              Stakeholders’ views of the ICO’s preparedness to enforce the law
              comparison                           2009                         2008                        2007
              Actual                                                                    35% excellent/very good
              Method           “And how would you rate the Information Commissioner’s Office in terms of
                               enforcement?”, asked of key stakeholders (universe 50). Percentage who say
                               excellent or very good on a scale of excellent, very good, good, fair and poor.
                               Measured by stakeholder perception survey (Jigsaw Research)




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Developing and improving
Communications objective: increase staff engagement
Indicator 11                            ICO engagement index
                                                     2009                  2007                  2005       Public Sector
                                                                                                                    Norm
Actual        Overall engagement                     56%                      -                     -                   -
              Job satisfaction                       61%                      -                     -                62%
              Recommend ICO                          61%                   37%                   55%                 60%
              Motivated                              60%                      -                     -                   -
              Gets the best out of me                52%                      -                     -                   -
              Feel valued                            44%                   36%                   39%                 38%
Method                                  ICO staff survey; questions equally weighted – the index is the average of favourable
                                        responses to the questions. Staff survey (IPSOS MORI)




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Appendix 3: Action plan
Updated December 2008 as part of business planning process

Key
Ongoing                          Chosen approach already in force
ST              Short term       Start within one year
MT              Medium term      Start within two years
LT              Long term        Start within three years


(Some actions contribute to more than one objective. For the sake of simplicity, and to avoid
repetition, actions have been put under the objective to which they contribute the most.
Details of who will do it, how and by when will be contained in separate documents, such as
the business plan and personal objectives. The numbering does not reflect priority).



1               Corporate focus: Educating and influencing


1.1             Communications objective: maintain awareness of rights
                (among individuals)


Strategy        Reach consumers / individuals with human interest stories
                and life events information
Tactics
•      Target consumer media (ongoing)
•      Support new guidance, publications, enforcement, decision notices etc,
•      continue to develop seasonal calendar and rebut myths, with media
       relations and web content (ongoing)
•      Promote the benefits of the Acts and the rights (ongoing)
•      Continue to create life-event based and topic-specific user journeys (eg
       health, criminal records, id theft) to lead individuals to relevant
       information (ST)
•      Refresh available easy-read publication and consider more (MT)
•      Identify the most at-risk group for data protection issues and devise a
       campaign to change behaviour (LT)


Strategy        Reach young people



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Tactics
•      Target youth media with human interest stories and life-event
       information (ongoing)
•      Update web content and youth pages with relevant stories (ongoing)
•      Annual Student brand ambassador project (ongoing)
•      Raise awareness of rights on others’ websites (links from our site added
       to others with reciprocal links; videos on youtube etc) (ST)
•      Habbo Hotel project – investigate (MT)
•      Explore social networking pages for ICO (MT)
•      Explore new ways of reaching young audiences with the data protection
       messages, eg gaming, msn etc (LT)
•      Explore ways of providing material to school age children via the
       education systems, eg redo Plumstones (MT/LT)


1.2            Communications objective: raise awareness of obligations
               (among organisations)


Strategy              Raise awareness among data protection and freedom
                      of information officers of the main DP and FOI
                      principles
Tactics
•      Support new guidance, enforcement, decision notices etc, continue to
       develop seasonal calendar and rebut myths, with media relations and
       web content (ongoing)
•      Contribute to and support Surveillance Society Action Plan (ongoing)
•      Contribute to and support Security of Personal Information Action Plan
       (ST)
•      Support data protection and freedom of information guidance writers to
       help produce effective guidance which is distributed appropriately (ST)
•      Seek opportunities to educate data controllers on the following
       principles: keeping data secure (principle 7), personal information is not
       kept longer than necessary (5), and personal information held is
       adequate, relevant and not excessive (3) (ST)



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•      Seek opportunities to educate freedom of information officers on the
       following obligations: to disclose information unless there is a good
       reason not to, to help and advise people who ask for information (ST)
•      Raise awareness of obligations on websites of other relevant
       organisations (MT)
•      Gain greater understanding of how data protection and freedom of
       information is managed in organisations (MT)
•      Analyse annual track information on awareness of obligations and
       investigate a sectoral league table (LT)
•      Consider a “How safe is your personal information?” ranking of
       organisations/websites/sectors etc (LT)


Strategy       Prepare for new notifications regime
Tactics
•      Work with IS and Notification department to develop the DUIS
       notification contact database to capture current email addresses for data
       protection and freedom of information officers, enabling swift contact
       with them when necessary (ST/MT)
•      Prepare for new notification fee system, amending web pages and
       publications, and informing those organisations on the notifications
       database (ST/MT)
•      Prepare for any changes to freedom of information, for example changes
       in designations of organisations for freedom of information purposes,
       pending government decision (ST/MT)


1.3            Communications objective: encourage good practice
               (among organisations and individuals)


Strategy              Give data protection and freedom of information
                      officers frequent, fresh and relevant information and
                      materials
Tactics




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•      Support new guidance, conferences and events, enforcement, decision
       notices etc, and continue to develop seasonal calendar and rebut myths,
       all with media relations, publications and web content (ongoing)
•      Support European Data Protection Day and International Right to Know
       Day (ongoing)
•      DP: Continue to support non-notifications project (ongoing)
•      DP: Contribute to and support Information Sharing Action Plan (ongoing)
•      Continue to create sector-based and topic-specific user journeys (eg
       education, health, councillors etc) to lead practitioners to relevant
       guidance (ST)
•      Prepare for international data protection week (ST)
•      Develop case studies and put on website (ST)
•      Devise GPN and guidance templates (ST)
•      DP: Notifications: complete scope of notifications project (ST)
•      DP: Communications plan to identify officers’ data protection questions
       and to disseminate the information proactively (ST)
•      DP: Contribute to and support Law Enforcement Activity Action Plan
       (ST)
•      Provide online toolkit to help officers and those requesting speakers to
       get the message across in their organisations (presentations, training
       materials etc) (MT)
•      FOI: Communications plan to help central and local government to
       respond to freedom of information requests (MT)
•      DP: Redo Blaggers DVD (LT)
•      DP: Consider road shows or seminars to target SMEs (LT)
•      FOI: Identify the key user groups of freedom of information (LT)


Strategy       Encourage consumer action and help people to help
               themselves
Tactics
•      Explain how to make an FOI request and complaint correctly (ST)
•      Campaign to encourage consumer action to demand good information
       rights practice (MT)



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Strategy       Influence stakeholders
Tactics
•      Develop international network of data protection communicators to
       support international policy work (ST)
•      Analyse top performing organisations: is there evidence of good data
       protection/freedom of information practice? (LT)


1.4            Communications objective: maintain the reputation of the
               ICO (among stakeholders)


Strategy       Maintain our profile and strengthen our brand
Tactics
•      Continue flagship events and publications eg Annual Report (ongoing)
•      Continue media training for staff (ongoing)
•      Work with regional offices to ensure communications are suitable for
       devolved governance (ongoing)
•      Identify convincing killer facts to support the ICO’s key messages (ST)
•      Develop our corporate identity to strengthen branding of internal
       communications and recruitment materials, and to encompass new
       methods of electronic communciations (ST)
•      Celebrate 25 years of the ICO (2009) (ST)
•      Assess practices, skills and staffing to ensure we can cater for 24 hour
       media and increasing web expectations and use (ST)
•      Prepare for the arrival of a new Commissioner (ST/MT)
•      Work in Scotland to help people to know where to go for data protection
       issues (MT)
•      Explore new communication channels for potential adoption by the ICO,
       such as text messages, wap/mobile pages, podcasts, blogs, interactive
       and social networking sites/groups etc (MT)
•      Strengthen monitoring of mentions of the ICO on the web (LT)


Strategy       Develop our stakeholder strategy



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Tactics
•      Complete the actions in the old stakeholder strategy (review speaking
       policy, refresh database, (ST)
•      Strengthen public affairs and create parliamentary liaison plan (ST)
•      Better evaluate and prioritise speaking engagements (MT)
•      Promote the benefits of good DP and FOI practice (eg CSR) (MT)
•      Target non-Executive directors and CEOs (MT)
•      Review and refresh the Stakeholder Strategy (and refresh contact
       coordinators role, and identify partnerships accordingly) (MT)
•      Run stakeholder perceptions survey (Next one 2010, MT)
•      Better understand who uses FOI and how it’s affected public authorities’
       behaviours (LT)


1.5            Communications objective: confidence in organisations’
               handling of information (among individuals)


Strategy       Show our teeth, show we’ve got a grip
Tactics
•              Consider how to rank most complained-about sectors and
               organisations (MT)
•              Find ways to demonstrate that information rights practice can
               damage or enhance an organisation’s reputation (MT)
•              Promote good practice news stories and case studies (MT)


2              Corporate focus: Resolving problems


2.1            Communications objective: increase customer satisfaction


Strategy       Improve the website
Tactics
•      Regularly refresh the FAQs on our website and put in most prominent
       and relevant place (ongoing)
•      Restructure the document library (ST)


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•      Create an online complaints form (ST)
•      Work with IS to modernise the website, eg DUIS, online payments etc
       (ST-LT)
•      Improve decision notice database (MT)
•      Create new secondary homepages for individuals and organisations,
       and rehome “what we cover“ contents (MT)
•      Explore the possibilities and benefits of wap compatible web content
       (MT)


Strategy         Understand our customers
Tactics
•      Run regular customer satisfaction surveys (ongoing)
•      Continue to provide staff with the ICO plain English course (ongoing)
•      Start mystery shopping and customer communications mapping (LT)
•      Consider web-based complaint logs to gather information in support of
       key information rights issues (LT)


3                Corporate focus: Enforcing


3.1              Communications objective: raise awareness of the ICO as
                 the enforcing authority (among organisations)


Strategy         Keep reminding them who we are and what we do
Tactics
•      Support new guidance, enforcement, decision notices etc, and continue
       to develop seasonal calendar and rebut myths, all with media relations
       and web content (ongoing)
•      Promote the e-newsletter and increase sign-up (ongoing)
•      Identify relevant consultations and ensure we respond (ongoing)
•      Publicise enforcement activity (ongoing)
•      Contribute to and support Action Plan on unlawful trade in confidential
       personal information (ongoing)
•      Publicise breach report figures (ongoing)


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•      Report data protection complaint handling figures in the same way as
       FOI (ST)
•      Identify simple vehicles to carry our messages in practitioners’ offices
       (eg posters, dvds) (ST)


4              Corporate focus: Developing and improving


4.1            Communications objective: increase staff engagement


Strategy       Supply the tools
Tactics
•      Continue to supply, support and develop: the framework for team
       meetings, ET contact sessions, corporate events, ICON, ICONNECT,
       Informer, staff surveys and key messages from main meetings (ongoing)
•      Continue regular market research programmes (including Annual Track,
       Staff survey etc) (ongoing)
•      Embed ICONNECT staff briefings in ICO culture (ST)
•      Refresh design of the Informer (ST)
•      Explore ways of measuring staff engagement, tailored to the ICO’s
       needs and in line with developing thinking (ST)
•      Prepare for Sharepoint platform for ICON (MT)
•      Work wth IS to develop and introduce internal discussion forums,
       collaborative software, wikis etc (MT)


Strategy       Encourage involvement
Tactics
•      Continue to look for opportunities to involve staff in corporate initatives,
       eg staff groups (ongoing)
•      Create opportunities for staff to accompany senior management on
       speaking engagements etc (ongoing)
•      Complete implementation of the ET programme in response to the staff
       survey (ST/MT)
•      Devise ways to celebrate successes (MT)



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•      Devise programmes to enable staff to get more personally engaged in
       data protection and freedom of information issues (MT)


Strategy       Develop the culture
Tactics
•      Build the ICO brand positioning and values internally and externally, and
       help staff to achieve the communication competency groups (ongoing)
•      Communicate change according to our policy (ongoing)
•      Prepare to take on new conference organising role in C&ER (ST)
•      Prepare staff for possible accommodation move (ST/MT)
•      Develop new ways of working in C&ER (programme leads, generic
       roles) (ST/MT)
•      Work with HR to improve and modernise recruitment communications
       materials (ST)
•      Complete diversity project and support with communications (MT)
•      Run masterclasses on how to do internal communications (MT)




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