I seem to recall reading somewhere that the requirement for IPs to register with the ICO in their personal capacities will cease with the implementation of GDPR. I cannot now find any reference to the point. Can anyone direct me to an authority on the point please?
Did you get an authoritative answer to this as i've seen mixed views? Some saying no, but then some saying yes as we will be acting in a personal capacity rather than agent - e.g. in relation to an IVA
My own views - for what they are worth - are these.
1 Technically, there is no need to notify to (register with) the ICO when GDPR takes effect.
2 But, under the Data Protection (Charges and Information) Regulations2018 (made under the authority of the Digital Economy Act 2017, a data controller will have to pay an annual levy to the ICO when GDPR takes effect.
(I am not sure quite what Orwellian use of language decrees that not to be registration.)
To me it is quite clear that an IP as office holder will be a data controller. Not just for VAs, but other procedures too. For example, as liquidator or administrator you will be compiling a personal file on each director for your D report.
So I think appointment taking IPs will need to pay the annual fee. As at present, I hope it should be possible for all IPs in a practice to be covered by the single fee. It may be possible to treat the firm and the IPs collectively as being covered by a single fee, but you'd probably need to speak to the ICO about that.
I expect existing registrations to run their course under the new regime.
The base fee is £2,900. That's what the ICO will charge you if you don't self-declare and claim the relevant exemptions. I expect most IPs to be eligible for the basic fee of £40 (with a £5 discount if you pay by DD).