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What next for RGDP’s DPO service?

In his blog post, Mark Chynoweth, General Manager of RGDP LLP, discusses GDPR and the requirements for RSLs to be compliant. 

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By Mark Chynoweth, General Manager of RGDP LLP

How time flies! The third anniversary of the introduction of GDPR passed in May and it is now well over 18 months since RSLs were designated as public authorities and became subject to Freedom of Information (‘FOI’) legislation.

Largely triggered by GDPR, RGDP, which stands for Really Good Data Protection, started providing Data Protection Officer (‘DPO’) services to RSLs in May 2018 with the focus firmly on data protection compliance. However, by early 2019 it was becoming apparent that RSLs were going to be designated as public authorities. This happened on 11 November 2019 and with it came a statutory requirement for RSLs to appoint a DPO and comply with the Freedom of Information (Scotland) Act 2002 (‘FOISA’).

It was therefore logical for RGDP to provide both data protection and FOI compliance services to our RSL customers and so the SFHA and RGDP jointly developed a discounted service package that would provide SFHA members with an independent DPO who would provide specialist advice and assistance with both GDPR and FOISA compliance, as well as the Environmental Information (Scotland) Regulations 2004.

RGDP is now the DPO for more than 30 RSLs in Scotland, steering them through their compliance with UK data protection laws, implementation of the Scottish Information Commissioner’s Model Publication Scheme whilst throughout, dealing with the steady drum-beat of data breaches and seemingly steady increase in FOI and subject access requests.   

Our DPOs are friendly, approachable and enthusiastic and our DPO service is agile, responsive and continually evolves. Whilst we still very much value on-site time with the customer, Covid-19 has resulted in a more ‘virtual’ service delivered via MS teams or Zoom with the DPO’s advice now catering for a hybrid mix of office based and home working.   

We have seen the EU’s GDPR replaced by the UK GDPR although the full effects of Brexit have probably yet to be seen. And for RSLs for whom RGDP has been the DPO for over a year, we have seen the emphasis gradually switch from establishing and improving compliance to maintaining a high level of compliance whilst embedding a culture of data protection and FOI understanding within the organisation, such that risk is reduced, compliance is maximised and the RSL is better able to manage the expectations of their tenants and other stakeholders.

RGDP LLP was established in early 2018 as a specialist provider of DPO services and it now serves a broad range of customers from the public, private and third sectors. RGDP is a Commercial Associate of the SFHA and a listed supplier with Public Contracts Scotland. We work in close association with the Glasgow, Edinburgh and Helensburgh based BTO Solicitors which has a highly regarded data protection team from whom RGDP’s DPOs can seek additional opinions to inform the advice that they provide to their customers.

If you are thinking of engaging an external firm to act as your DPO, the SFHA has negotiated a continuation of the significantly discounted service rates with RGDP. The service package is individually tailored to your data protection and FOI requirements, as well as your budget, but indicative costs are:

  • £375 per month plus VAT for a 12 month contract. You will be assigned a named DPO who will get to know you and who will provide you with continuity. They will be listed as your DPO on your ICO registration.
  • DPO time, including meetings or on-site visits, of four hours per month (12 visits/48 hours per year) – with flexibility to reallocate time as mutually agreed, e.g. if you ran to five hours one month you could use three the following month.
  • 30 minutes of ‘free’ telephone/email advice time per calendar month
  • £105 plus VAT per hour for DPO time over and above the 12 visits/48hours per year.
  • This represents approximately a 12% discount for SFHA members.

For more details, please contact Mark Chynoweth, the General Manager of RGDP LLP:

or view RGDP’s website: www.rgdp.co.uk

Here are some recent testimonials from RGDP’s customers:

 We cannot speak highly enough of RGDP. The reassurance of being supported by this level of expertise and responsiveness is invaluable” Glasgow based Housing Association

“We have been using the services of RGDP since 2019 and very much appreciate the support they offer.  Having access to specialist advice on what can be very challenging and complex cases has been invaluable” Carolyn Hughes, Housing Management Director/Depute CEO, Manor Estates Housing Association

“RGDP have been Abertay’s DPO since April 2019.  They provide advice on both Data Protection and Freedom of Information legislation.  We have monthly update meetings with Lesley where we discuss current issues and progress on our action plan and review documents and procedures.  Lesley also provides regular training to all staff.  We are able to access RGDP’s knowledge to assist us in dealing with Subject Access Requests, Freedom of Information Requests and Data Breaches” Marjorie Sloan, Corporate Services Director, Abertay Housing Association

“We’ve been receiving DPO services from RGDP for over 2 years.  It has been really beneficial having regular meetings with our DPO to ensure that data protection remains a key focus within our organisation.  The DPO service has proved to be invaluable as we’ve moved to new ways of working following the pandemic.  We have been able to access expert advice and guidance as soon as an issue arises” Martha Hutcheson, Corporate Services Manager, Glen Oaks Housing Association

“We are really pleased we appointed RDGP to provide GDPR guidance. Our Data Protection Officer is readily available to answer our queries and has been very supportive in providing tools and templates to assist with the process. The expertise and dedicated service we receive is invaluable to us as an RSL. The data protection laws are complex, but RGDP always guide us through the jargon, rules and due diligence. As a result, we have a robust tailor-made compliance framework, which is updated regularly and refreshed at every meeting. We are able to give our customers reassurance that we are meeting our legal obligations and I would highly recommend the services of RGDP to other similar businesses.” Director, Cathcart & District Housing Association

“We have been working with RGDP LLP for over a year now. Although we specifically work with Mark as our DPO, we are comforted that we are also benefitting from the wider knowledge and expertise of the entire team at RGDP. As DPO, Mark has assisted the Association with our data protection, freedom of information and environmental information compliance requirements allowing us to continually improve in these areas. Mark has also carried out training sessions for our Management Committee and Staff members and these have always received positive feedback. We find RGDP to be knowledgeable, thorough, responsive, organised and very good value for money for their services.” Corporate Services Director, Tollcross Housing Association

"Lister engaged RGDP two years ago for DPO and FOI services and we have been very impressed by their skill-set and dedicated, personalised service, which has been adjusted by mutual agreement as our needs and expectations have evolved” Alistair Cant, Director, Lister Housing Co-operative Ltd

“RGDP provide Ardenglen HA with a DPO service to assist with data protection and FOI compliance. Our DPO has been invaluable in helping us create a robust policy and procedure framework, providing staff training & advice sessions and advising us on responding to complex information requests” David Byfield, Director of Finance, Digital and Corporate Services, Ardenglen Housing Association

Bridgewater have been using RGDP since 2019 and our DPO is Mark Chynoweth.  Mark is very organised, efficient and methodical.  We meet monthly and he provides updates on all relevant issues in relation to GDPR, FOI and EIR.  When advice or assistance is needed, he always responds quickly and with clear instructions on how to handle any given situation.  He prepares our policies and procedures, provides training for our staff and Board but most importantly provides security if I feel out of my depth.  I have no hesitation endorsing RGDP.” Scott Currie, Corporate Services Manager, Bridgewater Housing Association

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