3.1 Assessment of remote audit/verification for on board Interim/Initial/Intermediate/ Renewal of SMC, ISSC and MLC
Remote audit/verification for Interim/Initial/Intermediate/Renewal of SMC, ISSC and MLC shall only be considered for situations, where it is impossible for the surveyor to attend the vessel. This requires exceptional circumstances such as COVID-19 restrictions, extreme weather condition etc.
The DMA handles requests for remote audits/verifications case-by-case. Requests shall follow the ‘Roadmap for processing requests for interpretations, equivalents and exemptions’ as laid out in the Annex to the RO agreement, section 6. The following factors shall be included in the request:
- The RO/RSO shall justify why a surveyor cannot attend the vessel.
- The RO/RSO must prepare a plan for how the audit can be performed remotely and a risk assessment of whether the audit can cover the full scope.
- In the risk assessment the DMA expects ROs/RSOs to take account for following considerations:
- The vessel is ready for remote audit/verification with regard to online connection for
- Sharing of documents
- Plans are in place for a “tour of the vessel.”
- Is it ensured that interviews can take place in solitary, to enable the crewmember to speak in confidence.
- Consideration for GDPR is in place when transferring data and documents to and from the RO/RSO auditor
- The vessel’s general performance.
- The qualifications of crew involved on board the ship and of the auditors performing remote audits/verifications.
- Availability of crew with reference to rest hour considerations.
3.2 Assessment of remote on-shore DOC audit.
The DMA can accept remote and partly remote audit of DOC, based on a request by the RO. The following factors shall be included in the request:
- It must be justified why a remote audit is requested. (I.e. travelling restrictions, synergy of auditing main and branch offices simultaneously etc.)
- The RO must prepare a plan for how the audit can be performed remotely and an assessment of whether the audit can cover the full scope.
- The DMA expects the RO to take into account at least the following considerations:
- It has been tested that an online connection can be established
- Sharing documents
- GDPR1 has been taken into account when sending documents to the RO.
- The company's general performance.
3.3 Communications with DMA in connection with remote audits
- If the RO/RSO assesses that, a remote audit/verification is possible a request shall be sent to the DMA (email@example.com). The request shall contain above listed considerations and RO/RSO’s recommendation of a remote audit/verification.
- The DMA will revert with refusal or accept (and conditions if any) – or additional questions.
- After the audit and if requested by the DMA, the RO/RSO reverts with a short notification to the DMA on the result, and on whether it has been decided to follow up with on-site attendance.
 Directive 95/46/EC (General Data Protection Regulation)