4. Data and Process Management
4.1 Introduction
FSS is responsible for the maintenance of the list of registered and approved feed businesses establishments, and records of official controls and enforcement activity.
In all instances FSS is considered the Data Controller for data collected via FMIS.
Agents are considered Data Processors when collecting, transferring or otherwise using data collected under the terms of the DSLA from 1 April 2021.
Agents must refer to and follow the conditions at clause 8 (Security/ Data Protection) within the DSLA and the signed Data Processing Agreement.
Agents are to assist the FSS in maintaining the accuracy of source data within FMIS by the accurate completion of all data fields and the submission of updated or missing information into FMIS where it is obtained at the time of visit.
4.2 The Feed Management Information System
FSS uses a Feed Management Information System (FMIS) for holding all feed establishment records.
Use of FMIS captures information in a centralised system to allow FSS to accumulate a national picture of feed activity and compliance.
Following account set up Authorised Officers can access FMIS via FSS supplied mobile devices, or any other capable and approved device.
The FMIS allows direct uploading of inspection information or, where no internet connectivity is available, will store the information locally until upload is possible.
Agents will be provided training on the use of the device and FMIS through videoconferencing or through in person meetings. Training materials and user guides are online within ArcGIS.
Should further assistance in the access to and use of the FMIS be required, contact feed@fss.scot in the first instance. Where assistance is required relating to the performance of the software the Agent may be directed to ArcGIS support.
4.3 List of Feed Establishments
The list will be maintained on the database supporting the FMIS and shall be updated in accordance with information received from FeBO’s, other government departments and agencies and Authorised Officers.
The online registration and approvals function on the FSS website allows unregistered businesses to submit requests for review by FSS.
The Agent is expected to support the maintenance of information and data within FMIS to help maintain an accurate list of feed establishments in accordance with paragraph 4.1.
4.4 Official Control Records
Official control reports shall be generated from the information gathered by officers in the conduct of their duties and saved on the FMIS using the feed inspection form templates.
Information must be gathered and processed in a manner consistent with GDPR and the provisions at paragraphs 4.7 and 4.8. All forms include a privacy statement, and officers should make the data subject aware of this provision.
Reports and other records relating to the business, for example, registration and approval forms and approval documentation (see Paragraph 5.3.8 of this manual), shall be stored in the FMIS or ERDM systems managed by FSS.
FSS shall ensure that records are maintained and processed, in line with the General Data Protection Regulations (GDPR) requirements or as required in any successor legislation. Registration and approval forms shall be kept for the duration of the existence of the feed business, and for 6 years after the closure of the business.
4.5 Records of Inspections
The mobile devices have been pre-loaded with the feed inspection form templates provided in FMIS. The system further provides the facility to take notes, capture photographic images and amend premises location detail.
The officer may either complete the form directly onto the mobile device whilst on site or record on a paper copy, completing the form on the mobile device within 5 working days of inspection. Further information on the recording of interventions is detailed in Chapter 5.
Documentation collected during, and because of, interventions shall be attached to the relevant premises file within the FMIS. Paper based information may be transcribed or scanned for inclusion within the FMIS system in accordance with the Scottish Government’s Transcription Framework Agreement or the use of BS10008 compliant scanning devices and subject to the provisions at paragraph 4.7.
4.6 Records of Sampling
Agents shall use the Scottish Food Sampling Database (SFSD) for the submission and recording of samples. When a targeted sample is taken during an inspection visit the officer should also record on the inspection record within FMIS that a sample has been taken.
Agents should refer to the FSS Sampling Guidance held within the FMIS information library which sets out the clear steps and stages to follow when taking and recording samples.
4.7 Other information
The FSS and Agents have agreed on a Data Processing Agreement (DPA) for the management of data under the new model.
In all instances FSS shall be considered the Data Controller for data collected, held, or processed under this agreement. Agents shall be Data Controllers for pre-existing data and data transferred to FSS during transition. Where data is collected while delivering Feed Official Controls under the new model, Agents shall function as Data Processors.
4.8 Freedom of Information
Agents shall refer to and follow the conditions at clause 9 within the DSLA in relation to Freedom of Information provision.