With the first transitional period shortly coming to an end and with all
organisations potentially receiving subject access requests to digitally
archived data I was wondering what mechanisms, e.g. methods of identifying
if a search of a digital archive is necessary, others might have
considered/adopted.
My current thoughts are that the request from the data subject could alert
me to the need to search an archive, but, where the data subject has not got
the necessary information (time parameters and archiving methodology) to
recognise that the data would be within an archive how will we identify the
necessity to search?
Could it be claimed that the necessary information to find the data had not
been provided by the data subject?
Would such a claim be fair to a data subject when the necessary information
about the existence of the data within an archive might easily be available
within the organisation the request is made to?
Will it be necessary to provide to data subjects details of
retention/archiving policies regarding the type of information they may be
requesting, or will it be up to the data subject to obtain that information
via a freedom of information request. (when that eventually applies)?
Ian W
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