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RCIPS loses bail book and finds it again

Informal Resolution | 12 August 2022

The RCIPS reported that its 2020 bail book went missing from the detention centre. It contained the names of an unknown number of prisoners along with the names of their arresting officers and their associated JMS numbers. The RCIPS took the position that the consequences to the data subjects were low. A search was undertaken of the detention centre but it had not been located. 

Our investigation found that the cabinet in which the book had been kept remained unlocked, and arrangements were made to immediately install a lock. There were no formal policies and procedures in place to manage access to the items. We concluded that the RCIPS had not adhered to the seventh data protection principle, which requires that "appropriate technical and organisational measures against accidental loss or destruction of, or damage to, personal data" be taken. As well, there were no arrangements in place to manage the retention and secure disposal of bail books. A new procedure involving the shift handover book will henceforth hold an officer accountable for the bail book, and we advised that a disposal schedule should be developed, approved and implemented without delay.

The case was reopened several months later when the lost bail book was found, but no adequate explanation was discovered or offered. We closed the case given the low risk to individuals’ rights and freedoms, and the high likelihood that the book remained in the hands of the RCIPS throughout this saga.