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Data Breach: Terms of Reference for investigation

Published Date: 16 September 2024

The Police Ombudsman has confirmed that Sarah Havlin, a solicitor with an extensive background in employment law and relations, has been appointed to undertake the independent investigation into the office’s recent data breach.

The Police Ombudsman has confirmed that Sarah Havlin, a solicitor with an extensive background in employment law and relations, has been appointed to undertake the independent investigation into the office’s recent data breach.

Mrs Havlin will investigate the breach which occurred on 29 August 2024, when a three-page Word document, containing details of the staff complement of the Police Ombudsman office's in May 2022, was inadvertently released to 22 people who were being invited to interview as part of a recruitment exercise. 

The document contained the forename initial and surname of all members of staff employed at that time, listed by the service area or team in which they work. If a member of staff was part-time, agency, contracted or seconded, it was also noted. 

A list of relevant staff movements, that is, those who had resigned, were due to retire, were on career breaks, moving between teams, or new starts, was also included. Some forenames were included in this information. 
No other personal information was contained in the document. 

The Office took immediate action to mitigate the breach which affected 160 current and former staff and confirmed that it would appoint an independent external investigator to review the incident and make recommendations.

Mrs Havlin has been appointed:

  • To investigate the process and actions which led to the breach occurring
  • To interview all parties deemed relevant to the investigation
  • To review the effectiveness of the immediate Police Ombudsman response to the  breach
  • To consider the effectiveness of the changes the Police Ombudsman plans to undertake to prevent any reoccurrence
  • To make recommendations to assist in the prevention of further data breaches
  • To provide a report on the investigation and findings to assist in lessons to be learned.

The investigation is anticipated to conclude within six weeks, after which point the Police Ombudsman will publish the findings and recommendations.

Sarah Havlin: Brief Biographical Details

Sarah Havlin is a solicitor with an extensive background in employment law and relations, and is currently the independent assessor of complaints for the Police Ombudsman. 

She has more than 15 years’ experience in both regulation, and judicial and quasi-judicial roles. She spent ten years as the Certification Officer of Northern Ireland, the statutory regulator of trade unions and employer associations with both investigative and judicial functions, and she is the current Chairman of Northern Ireland’s Industrial Court. 

Mrs Havlin has previously held public office as the Boundary Commissioner for Northern Ireland and as Local Government Boundaries Commissioner. She is an Associate of the Chartered Institute of Arbitrators and a Complaint Handler Member of the Ombudsman Association.