John,
We simply depend on Section 7(3) of the DPA, "such information as he may
reasonably require in order to locate the information".
A recent SAR asked for all info, including Council Tax. We responded
immediately, advising that any information held for the Council Tax purpose
would be supplied and invited the data subject to provide additional
information to identify other areas where we may hold information. In a
large local authority it would be almost impossible to respond to an
open-ended SAR. For example, I will not initiate an investigation in 150+
schools for educational records if I don't have confirmation that the data
subject was a student. In this case, I would expect the data subject to
advise that he was a student at X school, including year, etc.
It is likely that we will continue to operate in accordance with these
procedures (early advice from the OIC) or until the OIC or the courts advise
otherwise.
Alex Mitchell
North Lanarkshire Council
-----Original Message-----
From: J F Hitches [mailto:[log in to unmask]]
Sent: Wednesday, January 16, 2002 16:49
To: [log in to unmask]
Subject: Supplying information to locate data
Could Paul and Alex tell us which part of the DPA they are using
to get an exemption from supplying all data which is held.
A blanket SAE may be unwelcome but I did not think a data
controller has grounds under the Act to consider it unacceptable -
just the reverse, it is one of the millstones of the Act.
It may of course be different in Scotland and related to the FOI
Act there.....
John Hitches
J F Hitches
Data Protection Officer and
Information Security Officer
Kingston University
River House
53-57 High Street, Kingston upon Thames
Surrey, KT1 1LQ
Telephone/Fax: 020 8547 7768
E-mail: [log in to unmask]
The views expressed are those of the individual and
not necessarily those of the university.
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