Screening Reports

DPIA Screening - Performance Improvement Plan 2024-25

A Data Protection Impact Assessment (DPIA) is a process to help you systematically and comprehensively analyse your personal data processing and help you identify and minimise any data protection risks of a project.

You must do a DPIA before you begin any type of personal data processing that is “likely to result in a high risk.”

This set of screening questions will help you decide whether a DPIA is necessary. Please note, if there is a change to the nature, scope, context or purposes of your processing you will be required to complete this screening template again.

You will be accountable for the screening decisions you make. Therefore, it is critical that you document via “Explanatory Notes” the screening decisions you have made, providing logical reasons regarding whether to do a DPIA or not.

Section A - Project Details

Title of Project, Plan or Policy

Performance Improvement Plan 24-25

Is this an existing, revised or new project?

Revised

What is the purpose of the project, plan or policy?

e.g. intended aims or outcomes

Include any relevant background information here

Duty to Improve

Councils have a general duty to make arrangements to secure continuous improvement in the exercise of their functions (Local Government Action NI 2014).

Improvement in the context of the Act means more than gains in service output or efficiency, or in internal effectiveness. Improvement means an activity that enhances the sustainable quality of life and environment for ratepayers and communities.

For each financial year, councils must set Improvement Objectives, and have in place the arrangements to achieve them. These objectives must be framed to bring about improvement in at least one of the specified aspects of improvement outlined within the Act of strategic effectiveness, service quality, service availability, fairness, sustainability, efficiency, and innovation.

Our Improvement Objectives

Our Objectives for 2024-25 relate to improving our functions and services, and include:

1. People: We will work with partners to improve the lives of citizens.

2. Place: We will maintain and improve our local areas.

3. Planet: We will reduce our environmental impact and improve sustainability.

Our plan also includes statutory indicators and standards, as specified by the Local Government (Performance Indicators and Standards) Order (NI) 2015 as well as any ongoing actions from previous year’s Performance Improvement Plans.

Due to ongoing internal transformation activities, and high levels of external uncertainty, the actions described within the plan to deliver our objectives are subject to the availability of funding and finance throughout the year.

1. People - We will work with partners to improve the lives of citizens.

By:

  • Fostering local enterprise and economic growth.
  • Supporting skills development and improving employment outcomes.
  • Helping citizens lead healthy and active lives. 
  • Supporting people who are vulnerable or marginalised, and promoting an equal, diverse, inclusive, and accessible borough.

Why?

  • The actions set out to achieve this objective align with the key priorities identified in the consultation. They support priority groupings and provide opportunities for skills development and employment progression. They offer both health and wellbeing support and help to improve equality of opportunity, accessibility, and inclusivity.
  • Developing skills and job prospects, and support to reduce poverty, were two of citizens’ top five priorities for making the borough a better place to live in. Only 28% agreed the area is a good place for job opportunities (MEABC Citizens Survey 2022).
  • With the rising cost of living and the impact of the pandemic, the number of financially insecure households is increasing. Anecdotal evidence indicates that poverty is impacting families across the whole borough. Our Citizens Survey (2022) found on a scale to 10, half of respondents rated their satisfaction with financial health as being 5 or less.
  • This objective aligns with the Department for the Economy’s vision for Northern Ireland of creating jobs, increasing incomes, improving productivity, and providing opportunities for all.
  • In terms of wellbeing, almost 50% of residents said they want to see more support services for children and families, and/or people with disabilities.
  • The issue of inclusion was highlighted during the review of the Community Plan (2022), particularly for people with disabilities and learning difficulties. People from ethnic minority backgrounds, young people, and older people were also identified as being ‘at risk’.

What you will see:

  • Support to start your own business.
  • An active Mid and East Antrim Manufacturing Task Force.
  • Opportunities to take part in skills and employability programmes.
  • Support to lead a healthy and active life.
  • A borough that values, engages, and supports everyone.
  • Collaboration with the Mid and East Antrim Poverty Action Group.

How we will measure improvement:

  • 240 participants supported through start-up assistance via Go Succeed by 31 March 2025.
  • 107 jobs promoted through business start interventions by 31 March 2025.
  • At least 3 new Manufacturing Task Force members 31 March 2025.
  • £40,000 of Task Force member’s in-kind time contributions by 31 March 2025.
  • 200 people participating in employment and skills programmes by 31 March 2025.
  • 100 participants gaining employment via employment academies by 31 March 2025.
  • 150 participants securing qualifications by 31 March 2025.
  • MEA Aqua Strategy and Year 1 Action Plan (including the expansion of toddler and disability sessions) delivered by 31 March 2025.
  • MEA Age-Friendly Strategy and Year 1 Action Plan launched by 30 June 2024.
  • An Older Person’s Forum established by 31 December 2024.
  • MEA Age-Friendly Year 2 Action Plan confirmed by 28 February 2025.
  • 4 Autism-Friendly Action Plans implemented in 4 Council venues by 30 September 2024.
  • 4 additional Autism Champions developed within Council by 30 September 2024.
  • An Autism-Awareness initiative Communications Plan developed by 30 September 2024.
  • 4 arts and culture events delivered to address loneliness and improve accessibility by 31 March 2025.
  • 12 outdoor events to involve a wide range of abilities by 31 March 2025.
  • Attendance at Poverty Action Group meetings and support of initiatives.

Strategic links:

Programme for Government:

  • Everyone can reach their potential.
  • People want to live, work, and visit here.
  • Our economy is globally competitive, regionally balanced and carbon neutral.
  • We all enjoy long, healthy, active lives.
  • We have a caring society that supports people throughout their lives.
  • We have an equal and inclusive society, where everyone is valued and treated with respect.

Community Plan:

  • Progress in education and employment
  • Tourism and the economy
  • Good health and wellbeing
  • Community safety and cohesion
  • Tackling poverty
  • Prioritising the most vulnerable
  • Addressing inequalities

Corporate Plan:

  • People
  • Place
  • Performance

Aspect of Improvement:

  • Strategic effectiveness
  • Service availability
  • Fairness

2. Place - We will maintain and improve our local areas.

By:

  • Enhancing our amenities, parks, and open spaces.
  • Bolstering our town centres.
  • Nurturing community-led tourism
  • Delivering an effective and efficient Planning Service.

Why?

  • The actions set out to achieve this objective align with the key priorities identified within the consultation. Improvements to playparks and provision for outdoor recreation (particularly for young people) was a high priority for citizens. Actions will also support, improve, and revitalise the borough’s town centres.  Provision must be inclusive, accessible, regionally balanced, and in line with citizen needs.
  • Supporting and developing activities for children and young people, delivering clean and attractive streets and towns, and supporting our parks, green spaces and the natural and built environment, were within citizens top five priorities for making the area a better place to live in (MEABC Citizens Survey 2022).
  • More than a third would like to see more access to green spaces, such as parks and forests (MEABC Citizens Survey 2022).
  • Community tourism can help boost local economies by encouraging visitor footfall, increasing jobs, and generating revenue for local businesses. This can help increase civic pride in a local area and develop more sustainable and prosperous communities.

What you will see:

  • New or improved playparks.
  • Greater provision for outdoor recreation.
  • Delivery of the Town Centre Revitalisation Scheme.
  • Delivery of the Carrickfergus Townscape Heritage Initiative Scheme.
  • Locally led tourism.
  • Achievement of our statutory Planning Service targets.

How we will measure improvement:

  • Clough playpark completed by 31 May 2024.
  • Marine Gardens playpark completed by 31 August 2024.
  • Larne Skate Park completed by 31 October 2024.
  • 2 additional new or refurbished playparks completed by 31 March 2025.
  • Carnlough, Glynn and Portglenone MUGAs or kickabouts completed by 30 June 2024.
  • Carrickfergus Amphitheatre 2G pitch upgraded to 3G by 31 July 2024.
  • Phase 1 of the Cullybackey to Galgorm Greenway completed by 30 September 2025.
  • Development of Carnfunnock Country Park completed by 31 March 2026.
  • Sound systems installed in Ballymena and Carrickfergus town centres by 30 June 2024
  • 2 street art schemes in Ballymena and Larne town centres by 31 July 2024.
  • Feature lighting installed in Ballymena and Larne town centres by 30 September 2024.
  • Additional funding application submitted to the Department for Communities by 30 September 2024.
  • 25 businesses or groups utilising Pop-Up Shop opportunities by 31 March 2025.
  • 15 events or activities held within Ballymena, Carrickfergus, and Larne town centres by 31 March 2025.
  • 10 buildings of historical and architectural interest restored in Carrickfergus by 31 May 2024.
  • Increased floor space for retail, commercial or residential use in Carrickfergus by 30 June 2024.
  • Closing event and publication issued on the Carrickfergus Townscape Heritage Initiative by 30 June 2024.
  • Neighbourhood Tourism Scheme launched by 31 October 2024.
  • 3 local Neighbourhood Tourism participants by 31 March 2025.
  • A processing time for major planning applications within an average of 30 weeks by 31 March 2025.
  • A processing time for local planning applications within an average of 15 weeks by 31 March 2025.
  • At least 70% of enforcement cases concluded within 39 weeks by 31 March 2025.

Strategic links:

Programme for Government:

  • Our children and young people have the best start in life.
  • We all live long, healthy, active lives.
  • People want to live, work, and visit here.
  • We live and work sustainably, protecting the environment.

Community Plan:

  • Good health and wellbeing
  • Tourism and the economy
  • Prioritising the most vulnerable

Corporate Plan:

  • People
  • Place
  • Performance

Aspect of Improvement:

  • Strategic effectiveness
  • Service availability
  • Fairness
  • Sustainability

3. Planet - We will reduce our environmental impact and improve sustainability

By:

  • Moving towards cleaner energy and reducing our consumption.
  • Delivering an effective and efficient Waste Service.
  • Supporting biodiversity.
  • Reaching environmental standards and targets.
  • Sharing learning and best practice.

Why?

  • The actions set out to achieve this objective align with the key priorities identified within the consultation. They demonstrate how the Council is leading by example, whilst also working to engage and educate on sustainability. They assist the development of the borough’s EV charging network, they focus on providing an effective and efficient waste management service, and they demonstrate support for the biodiversity within the borough.
  • Our citizens identified help to reduce consumption, waste and litter, and awareness and assistance in tackling climate change as the two most important things the Council could do to be more environmentally friendly. Adopting environmentally sustainable transport ranked third and protecting plants and animals ranked fourth (MEABC Citizens Survey 2022).
  • Measures to address climate change, environmental awareness, and the importance of respect for the local and natural environment, were points raised throughout the Community Planning Review (2022) consultation.
  • The phase out date for the sale of new petrol and diesel cars is 2035.

What you will see:

  • Energy-saving and clean energy projects within Council buildings.
  • Expansion of electric vehicle chargepoints within the borough.
  • Achievement of statutory Waste Management targets.
  • Delivery of our Tree and Woodland Management Strategy.
  • Achievement of environmental targets and accreditations, where viable.
  • Opportunities to engage in environmental educational programmes.

How we will measure improvement:

  • 6 energy-saving projects delivered by 31 March 2025.
  • 4 clean energy projects delivered by 31 March 2025.
  • Approximately 77,000kg CO2e carbon savings by 31 March 2025 (lifecycle savings – 1.5m kg).
  • Approximately £80,000 savings through energy projects by 31 March 2025 (lifecycle savings - £1.6m).
  • 12 fast chargers procured through the On-Street Residential Chargepoint Scheme (ORCS) by 30 September 2024.
  • Installation date for ORCS chargers confirmed by 31 March 2025.
  • 6 upgraded charge stations through ESB by 31 March 2025.
  • At least 50% of household waste collected is sent for recycling by 31 March 2025.
  • A maximum of 16,387 tonnes of biodegradable collected municipal waste sent to landfill by 31 March 2025.
  • Less than 75,797 tonnes collected municipal waste arisings by 31 March 2025.
  • 5000 trees planted within the borough by 31 March 2025.
  • Re-certification of International Management Standard ISO14001 by 30 August 2024.
  • A minimum of Gold Status in the NI Environmental Benchmarking Survey by 30 November 2024.
  • Gaps identified in the 2023 NI Environmental Benchmarking Survey addressed by 31 October 2024.
  • 10 community engagement sessions held on Waste and Recycling, and Climate and Sustainability 31 March 2025.
  • Support for the Eco-Schools programme, with a 5% increase in the number of schools with Green Flags by 30 June 2025.
  • Delivery of 5 circular economy waste initiatives by 31 March 2025.

Strategic links:

Programme for Government:

  • We live and work sustainability, protecting the environment.
  • We all enjoy long, healthy, active lives.
  • Our economy is globally competitive, regionally balanced and carbon neutral.
  • People want to live, work, and visit here.

Community Plan:

  • Good health and wellbeing
  • Community safety and cohesion
  • Valuing our environment

Corporate Plan:

  • Planet
  • Performance

Aspect of Improvement:

  • Strategic effectiveness
  • Service availability
  • Sustainability

Which MEABC Department owns or holds responsibility for this project, plan or policy?

Ownership of this plan is Council wide. Each Improvement Objective is made up of a number of actions and measures, each with an assigned responsible officer. Overall responsibility for each Improvement Objective is assigned at Director level to Senior Responsible Officers (SROs), as detailed within the plan.

The Corporate Performance & Improvement team will assume responsibility of reporting progress against the plan on a quarterly basis.

Section B

Does this project, plan or policy involve the processing of personal data?

No

This DPIA screening relates to the Performance Improvement Plan document at a strategic level. Any instances where personal data may be processed will come to fruition in the projects emanating from the Improvement Objectives. It will be the responsibility of the project SROs to ensure that a DPIA screening is carried out, if not already done so.

If the answer to this question is ‘No’, you do not need to conduct a DPIA. Please proceed straight to Section E.

If the answer to this question is ‘Yes’, please proceed to Section C.

Section C: Questions 1 – 13

For questions 1 to 13, a DPIA MUST be carried out if the answer is YES. Your documentation should explain very clearly whether there are any indicators that a type of processing will likely result in high risk. See Appendix A for Information Commissioner’s Office (ICO) examples of processing “likely to result in high risk.”

For some of these questions, the answer will only be “yes” if the processing occurs in combination with criteria (see questions 14 to 22) in the Article 29 Data Protection Working Party’s European Guidelines. 

 

Screening Questions – will the project:

Yes/No

Explanatory Notes

1

Use systematic and extensive profiling or automated decision-making to make significant decisions about people?

 

 

2

Process special category data or criminal offence data on a large scale?

 

 

3

Systematically monitor a publicly accessible place on a large scale?

 

 

4

Use innovative technologies or the novel application of existing technologies? 

(Note: A DPIA is required where this processing is combined with any of the criteria from the European guidelines.)

 

 

5

Use profiling, automated decision-making or special category data to help make decisions on someone’s access to a product, service, opportunity or benefit?

 

 

6

Carry out profiling on a large scale?

To decide what constitutes ‘large scale’ you should consider and include information on factors such as:

-the number of individuals concerned

-volume of data

-variety of data

-duration of processing

-geographical extent of processing.

Also see examples in ICO’s guidance of processing/projects they consider to be large scale.

 

 

7

Process biometric data?

(Note: A DPIA is required where this processing is combined with any of the criteria from the European guidelines.)

 

 

8

Process genetic data?

(Note: A DPIA is required where this processing is combined with any of the criteria from the European guidelines.)

 

 

9

Combine, compare or match personal data from multiple sources?

 

 

10

Process personal data without providing a privacy notice directly to the individual?

(Note: A DPIA is required where this processing is combined with any of the criteria from the European guidelines.)

 

 

11

Process personal data in a way which involves tracking individuals’ online or offline location or behaviour?

(Note: A DPIA is required where this processing is combined with any of the criteria from the European guidelines.)

 

 

12

Process children’s personal data for profiling or automated decision-making or for marketing purposes, or offer online services directly to them?

 

 

13

Process personal data which could result in a risk of physical harm in the event of a security breach?

 

 

Section D: Article 29 Data Protection Working Party’s European Guidelines

When considering if your processing is “likely to result in high risk,” you should consider the European guidelines.

These define nine criteria of processing operations likely to result in high risk. In most cases, a combination of two factors indicates the “need” for a DPIA.

Although this is not a strict rule.

Therefore, if the answer to any of questions 14 to 22 is “yes” a DPIA should be “considered.”

Your documentation should explain very clearly whether there any indicators that a type of processing will likely result in high risk.

See Appendix B for the Article 29 Data Protection Working Party’s examples of processing “likely to result in high risk.”

 

Will the project:

Yes/No

Explanatory Notes

14

Involve evaluation or scoring?

 

 

15

Involve automated decision-making with legal or similar significant effect?

 

 

16

Involve systematic monitoring?

 

 

17

Involve sensitive data or data of a highly personal nature?

 

 

18

Involve data processing on a large scale?

 

 

19

Involve matching or combining datasets?

 

 

20

Involve processing of data concerning vulnerable data subjects*?

(Note: staff may be considered to be vulnerable data subjects due to the imbalance of power between employer and employee.)

 

 

21

Use innovative technological or organisational solutions?

 

 

22

Prevent data subjects from exercising a right or using a service or contract?

 

 

Section E: Findings

Is a DPIA required?

No

Note: Data Protection legislation and Information Commissioner’s Office guidance state that you should seek your Data Protection Officer’s advice when you need to do a Data Protection Impact Assessment.

Final Comments

This DPIA screening relates to the Performance Improvement Plan document at a strategic level.  Any instances where personal data may be processed will come to fruition in the projects emanating from the Improvement Objectives.  It will be the responsibility of the project SROs to ensure that a DPIA screening is carried out, if not already done so.

DPIA Screening undertaken by:

Business Planning & Performance Manager

Date Completed:

24 April 2024

 

DPIA Screening approved by:

Assistant Director of Citizen Focus

Date Completed:

25 April 2024