In brief
- Regulation: GDPR.
- All local authorities, regardless of their size, are concerned.
- Maintaining a multi-service register.
- Governing children's data.
- Governing video surveillance.
- Specific caps may apply to public bodies under national law.
Regulatory deadlines
The key dates of this regulation.
May 2018
Entry into application
In forceWhat does GDPR cover?
The local authority acts on the basis of public interest missions and legal obligations. Its processing activities cover all services, with particular challenges around children's data and video surveillance of public spaces.
The DPO is mandatory for public bodies and frequently shared between local authorities.
Is the 'Local Authority' sector affected?
All local authorities, regardless of size, are concerned. Small municipalities are too, often with limited resources that justify a shared-services approach.
Service providers (business software vendors) are data processors and must be governed accordingly.
Detailed obligations
Maintain a multi-service register
Document all processing activities across all of the local authority's services.
Govern children's data
Handle after-school and school catering data with vigilance.
Regulate video surveillance
Define the legal basis, information, proportionality and retention periods for images.
Oversee subcontractors
Sign DPAs with business software publishers and hosting providers.
Appoint a DPO
Appointing a DPO, potentially shared between public bodies.
Sanctions & risks
Specific caps may apply to public bodies under national law. A breach involving children's data or video surveillance data is particularly sensitive.
Common mistakes in the sector
- 1Partial register. Omitting services from the register.
- 2Disproportionate video surveillance. Filming beyond what is necessary or retaining footage for too long.
- 3Children's data neglected. Failing to regulate after-school activities.
- 4DPO missing. Failing to appoint a DPO where mandatory.
Practical case
A municipality deploys video surveillance without a clear legal basis or defined retention period. Remediation requires justifying the system, informing the public, limiting the retention period, and registering it in the record of processing activities.
Compliance roadmap
- 1
Map. Inventorying the processing activities of all departments.
- 2
Prioritise. Prioritise children and video surveillance.
- 3
Contractualise. Govern business software publishers.
- 4
Secure. Appropriate retention periods and security.
- 5
DPO. Designate or pool.
Frequently asked questions
Yes, but it can be pooled across local authorities.
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