But don't forget - the requirement is to provide a permanent copy of the personal data, not necessarily a photocopy of the document of original entry!
Verbal guidance from OIC on several occasions at public meetings / events that a retyped précis of a large document is acceptable as long as it truly reflects the original - maybe someone has that in writing somewhere?
Or where one or more exemptions applies to part but not all of a document, a retyped version of only the personal data to be disclosed, or even a 'merged' version of several documents to anonymise the identity of one or more third parties e.g. subjective information in references.
Couldn't you retype the placement report content but clearly marked that it is information provided to the data subject in response to SAR and does not constitute a reference???
Kirsty E Gray
Data Protection Officer
National Care Standards Commission
Note: comments for discussion and debate only and do not necessarily reflect the corporate position of NCSC nor constitute legal advice.
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