Sun, 29 Jun 2008

Waiting for the actual removal of DNA, fingerprints and PNC records process map

After having been in the very lucky position of managing to get my DNA samples destroyed and profile deleted, I was shocked to find the destruction and removal steps to be ad hoc. This left me with little confidence in the effectiveness of the actions taken in such circumstances so I pressed for a process to be created and published. See How to delete your DNA profile (El Reg) for more details. In September 2007, I started an email conversation with a Senior Information Manager at the Metropolitan Police Service's Specialist Crime Directorate (SCD12); he wrote:

[T]here is no process map in existence for this practice. [...] An exceptional case process map will be available on the MPS Publication Scheme early 2008. The MPS website address is if you should wish to view it when it appears.

I noticed that on Friday (2008-06-27), Version .1 of the Exceptional Case Requests - Consideration for the Removal of DNA, Fingerprints and PNC Records had been published by the Specialist Crime Directorate / SCD12 on the Metropolitan Police Service Freedom of Information Publication Scheme page. The document was created on 2007-09-17, at the very same date I received the email above. This publication, disappointedly, still focuses only on the process to decide if a case is exceptional enough for the Police to consider relenting and exercising its discretion to ‘accede to requests from data subjects for their DNA and fingerprints to be destroyed, together with the deletion of the supporting entry on the Police National Computer (PNC)’:

All requests for the consideration of deletion of such records received by the MPS will be referred to the Exceptional Cases Unit [SCD – Freedom of Information Act Compliance Unit] for processing in accordance with National Policy. Although exceptional cases will be extremely rare the circumstances will be considered and the Commander for Operational Information, Intelligence and Learning will make the final decision on behalf of the Commissioner. They might include cases where the original arrest was found to be unlawful. Additionally, where it is established beyond doubt that no offence existed, that might, having regard to all the circumstances, be viewed as an exceptional circumstance.

A flow chart for this process was published in the Retention Guidelines for Nominal Records on the Police National Computer, incorporating the Step Down Model.

We are no more early 2008 and still awaiting a process map describing in details what happens after the Police reaches a decision to delete. Which Police department and contractors are involved, what actions they each take, how it is ensured removed data is not restored in case some computer tapes need to be restored, how it is all supervised, etc.

P.S. If you want to follow links from the ‘Further information’ section of the Consideration for the Removal of DNA, Fingerprints and PNC Records, you'll have to retype them as all documents from the MPS are locked preventing copying/pasting from them without the proper password. What could be the reason? Here are a direct links to the Home Office National DNA database documents and other information page and the Exceptional Case Procedures for Removal DNA, Fingerprints and PNC Records Word file.

In another related news, GeneWatch has published a detailed deconstruction of Gordon Brown's deliberately misleading claim that not retaining genetic profiles of innocent people on the National DNA Database (NDNAD) would have led to 114 murderers getting away. See also UKLiberty's Gordon’s civil liberties speech to the IPPR for an analysis of other parts of his speech.

Meetings notes from the recently established NDNAD Ethics group are available on The National DNA Database Ethics Group page at the Home Office.

Another DNA related blog post this month: Calls for a new regulatory framework to challenge DNA samples and profile retention.

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