ICO publishes subject access code of practice
The Information Commissioner’s Office (ICO) has suggested a 10-step approach when considering how to respond to a subject access request.
Identify whether a request should be considered as a SAR; make sure you have enough information to be sure of the requester’s identity; if you need more information from the requester to find out what they want, then ask at an early stage; if you’re charging a fee, ask for it promptly; check whether you have the information the requester wants; don’t be tempted to make changes to the records even if they’re inaccurate or embarrassing… do consider whether the records contain information about other people; consider whether any of the exemptions apply; if the information includes complex terms or codes, make sure you explain them; provide the response in a permanent form where appropriate.
Some of the more interesting points covered in the code include…
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