17. Who is responsible for delivery and monitoring this policy
The Monitoring Officer as Senior Responsible Officer has oversight of:
- the integrity of the process in place within the local authority for the management of CHIS;
- compliance with Part II of the Act and with the Codes;
- oversight of the reporting of errors to the relevant oversight Commissioner and the identification of both the cause(s) of errors and the implementation of processes to minimise repetition of errors;
- engagement with the Office of the Surveillance Commissioner (OSC) inspectors when they conduct their inspections, where applicable; and
- where necessary, oversight of the implementation of post-inspection action plans approved by the relevant oversight Commissioner.
- ensuring that all authorising officers are of an appropriate standard in light of any recommendations in the inspection reports prepared by the OSC.
- where an inspection report highlights concerns about the standards of authorising officers, this individual will be responsible for ensuring the concerns are addressed.
The Deputy Monitoring Officer as the RIPA Co-ordinating Officer will:
- Maintain the central record of authorisations (see Section 8).
- Have oversight of all applications and authorisations for directed surveillance or use of CHISs, including preparation of the judicial application / order form.
- Providing general advice to investigating officers.
- Ensure a programme of RIPA training for all investigating officers and authorising officers (including the SRO) and the Co-ordinating Officer.
- Raise awareness of RIPA requirements throughout the organisation and ensuring staff are aware of the policy and receive appropriate support and training (with support from Heads of Service).
The Chief Executive, Deputy Chief Executive, Monitoring Officer and s.151 Finance officer are the council’s three authorising officers. Only the Chief Executive may authorise surveillance which involves confidential information (see section 5.3). Records of all authorisations, reviews and cancellations are to be kept by the RIPA Co-ordinating Officer.
Through the review provisions set out in the policy. The Council is also monitored by the Office of the Surveillance Commissioner which inspects approximately three yearly at the current time (last inspection Summer 2017).
It is also recommended that the Audit and Governance Committee should review the authority's use of RIPA, and the policy on an annual basis. Councillors must not be directly involved in, or have details disclosed to them of specific authorisations or engage in the authorisation process.