Regulation of Investigatory Powers Act (RIPA) action plan – March 2024

Objective 1. Policy, procedures and documents:

Action

Action owner

Target date

Comments

Completed date

1.1 Add the escalation in the authorisation level for Juvenile and Vulnerable CHIS and the variation of the authorisation period for a Juvenile CHIS (May 2021 action)

RIPA Senior Responsible Officer (Head of Legal and Democratic)

Revised to April   2024

 

Added into revised policy and procedures which is to be presented to Joint Audit and Governance Committee 15th April 2024

 

1.2 Add fuller explanation of
IPCO’s full oversight role (May 2021 action)

RIPA Senior Responsible Officer (Head of Legal and Democratic)

Revised to April 2024

 

Added into revised policy and procedures which is to be presented to Joint Audit and Governance Committee April 2024

 

1.3 Add explanation of FOI Act and requests for disclosure of IPCO inspection reports needing IPCO DPO consultation, as per IPCO Spring 2023 newsletter

 

Present to April 2024 JAGC for policy review.

 

Added into revised policy and procedures which is to be presented to Joint Audit and Governance Committee April 2024

 

1.4 Ensure policy covers data handling, retention, review  and destruction (see IPCO annual report page 94) includes compliance assurance to JAGC annually

 

Present to April 2024 JAGC for policy review.

 

 

 

 

Objective 2. Training and awareness:

Action

Action owner

Target date

Comments

Completed date

2.1 Deliver RIPA update training for investigating and legal officers (May 2021 action)

 

RIPA Co-ordinator

(Deputy Head of Legal (Operational)

May 2021

 

Training delivered by Ben Fullbrook of Landmark Chambers. Invitations extended to approximately 30 investigating and legal officers who either attended the online session or (along with other officers) have the opportunity to watch the recording.

Further training for officers being arranged with Cornerstone Chambers for April 2024

13 May 2021

2.2 Deliver training specifically for RIPA authorising officers

 

RIPA Co-ordinator

(Deputy Head of Legal (Operational)

December 2021

Revised to

April 2024

 

Dependent upon the review and confirmation of new authorising officers by the Strategic Management Team

 

 

2.3 Deliver refresher training for investigating and legal officers and authorising officers

 

RIPA Co-ordinator

(Deputy Head of Legal (Operational)

January 2025 and annually

 

 

2.4 Develop a plan for raising RIPA awareness across the organisation to improve compliance and prevent unauthorised activity, including consideration of targeted briefings of relevant teams and general staff updates

 

RIPA Co-ordinator

(Deputy Head of Legal (Operational))

April 2024 and annually

Signposting policy and procedures to all via Intranet and staff news letter April 2024

 

2.5 Ensure service areas are clear in what actions are acceptable before RIPA should be considered for use of internet as part of investigations. (see page 93 of IPCO annual report from march 2023)

 

RIPA Co-ordinator

(Deputy Head of Legal (Operational)

April  2024 and annually

 

 

 

Objective 3. Records management:

Action

Action owner

Target date

Comments

Completed date

3.1 Add the product of directed surveillance to the corporate/services guidance on data management, records of processing activities and retention policies and update the RIPA policy and procedures as required.

RIPA Senior Responsible Officer (Head of Legal and Democratic)

April 2024     

 

 

 

3.2 Consider incorporating the management of such product within the Central RIPA Register

RIPA Senior Responsible Officer (Head of Legal and Democratic)

March 2024  

 

Discussed and agreed draft changes now being prepared