I think the answer is Yes, per the IOC legal guidance part 4.1.5
"There is no reason why an intellectually capable adult should not make a
request through an agent. If a data controller who receives such a request
is satisfied that the individual has authorised the agent to make the
request, the data controller should reply to it."
I always insist on a signed consent form before releasing documents.
Generally, once satisfied about the nature of the request, I've sent
acknowledgement, the copies & covering letter, etc. direct to the data
subject.
However I've had over 120 requests for copies of personal data in housing
files since January from one particular firm of Solicitors. They are
canvassing our estates encouraging tenants to make damages claims against
the council over repairs. They know they will be able to gather more
information and earlier through SAR rather than through disclosure of
evidence rules.
I send documents with an itemised list of contents and covering letter to
the Solicitor and copy the list & letter only to the tenant.
Kirsty E Gray
Information Rights Officer
Gateshead Council
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