Information Commissioner's Office
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Collective leadership at the ICO

Blog posted by Christopher Graham, Information Commissioner, October 19, 2015

The next few weeks will see some big changes in the leadership of the Information Commissioner’s Office – changes of personnel and changes of approach. I want to take this opportunity to tell our stakeholders about what’s afoot and to explain my thinking.

From next month, I will be assisted by a Senior Management Team of 12 colleagues. This replaces the smaller Executive Team, currently two Deputy Commissioners and a Deputy Chief Executive, with which I have been working over the past six years. The change marks a move towards a more collective model of leadership at the ICO which is now a significantly bigger and more complex operation than the one I joined in 2009.

A prompt for the change is the fact that I am losing two very senior and experienced colleagues – the two Deputy Commissioners, Graham Smith and David Smith, respectively Directors of Freedom of Information and Data Protection at the ICO.

This is Graham Smith’s last week at the ICO. He is leaving after 14 years as Deputy Commissioner to take up a position with the European Ombudsman in Brussels. Graham led the work to establish the ICO as the Regulator for the Freedom of Information Act 2000 and he has had responsibility for our Policy Delivery function across both freedom of information and data protection.

Then next month, the other Deputy Commissioner, David Smith, retires after 25 years’ service at the ICO and 10 years as Deputy Commissioner. David has pioneered the ICO’s very practical approach to regulating data protection and he has led our relationships with key stakeholders through our Strategic Liaison function.

Replacing these two experienced colleagues would have been a challenge in any event, but it has been complicated by the delay in concluding the Triennial Review, launched a year ago at the initiative of the Cabinet Office. I am confident that the report on the ICO will be published in due course. But one of the matters under consideration in that Review was Lord Justice Leveson’s recommendation that the Information Commissioner should no longer be constituted as a ‘corporation sole’. Under the circumstances, I felt I could not simply replace the two Smiths with like for like appointments.

Instead, and to promote the greater shared decision making advocated by Leveson, I have widened the leadership cadre at the top of the ICO and opted for much greater collective consideration of regulatory matters. Stakeholders will still find the ICO an expert partner and our full range of information rights functions continue – but with wider involvement from other departments. Overall, the result should be a better joined up ICO.

Clearly I need the support of a Deputy Commissioner with full delegated authority and I am delighted to announce that I am designating Simon Entwisle, current Deputy Chief Executive Officer at the ICO, as Deputy Commissioner and Deputy CEO with effect from 1 November.

This new leadership structure is designed to build a strong platform for whatever changes are required of the ICO in the next year or so. Whatever the recommendations of the Triennial Review, we can anticipate that the new EU data protection Regulation will oblige the ICO to organise itself somewhat differently. This is simply because the new obligations to be placed on data protection authorities will oblige the ICO to do some things differently. But, until the negotiations in Brussels are concluded, we cannot know quite how differently we will need to be organised.

One more change coming over the horizon. At the end of June 2016, I will have done my seven years as Information Commissioner. I am assured by our sponsorship team at the Department of Culture Media and Sport that the advertisement for my successor will be published shortly.

The next Information Commissioner will have the challenge of leading the ICO through an exciting period of change as the organisation gears up to apply the new DP Regulation. Add that dimension to what is the roller coaster ride that upholding information rights in the digital age involves, and DCMS will be looking to recommend the strongest possible field of candidates.

Meanwhile, I have lots still to do facing the immediate demands of dealing, for example, with the commission on the Freedom of Information Act, forthcoming surveillance legislation, what to do about international data transfers and Safe Harbor, nuisance phone calls, charity fundraising – and making sure I leave the ICO as a well-oiled machine, running at optimum efficiency and effectiveness. Our new collective leadership is helping me to do just that.


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