thanks to those who replied this post.
It seems to be down to interpretation of 7(4), 7(5) and 7(6).
Disclosure is fairly straightforward for front office staff who have been involved with the data subject. Or others who have been named in previous correspondence, etc.... etc...
But I'm still not sure that it is "reasonable in all the circumstances" to disclose the name of a back office employee who has had no previous contact with the data subject. Particularly where they play a supporting role and are never likely to be in contact with the data subject, and they have refused consent for the disclosure.
I don't suppose anyone is aware of any relevant case law ?
thanks again,
Tommy Kennedy.
> Subject: subject access - (employee) third party rights
>
> When complying with a subject access request, employee names will often
> crop up on letters, reports, etc... to be provided to the subject.
>
> Is there any reason why employees shouldn't receive the same 3rd party
> rights as others ?
>
> e.g. an employee asks for their name to be withheld.
> It is not critical to the access request and seems reasonable in the
> circumstances.
> But the data subject is insisting on it being provided.
>
> I seem to remember some previous discussion suggesting that employee names
> should not normally be withheld.
> But can't remember the logic and can't find it in the archives.
>
> any offers gratefully received.
> thanks
> Tommy Kennedy.
>
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