This may be stating the obvious but I think confusion may arise because
people interpret S8(3) and S8(4) as defining vexatious requests. If a data
subject deliberately submits requests regularly at unreasonable intervals
then it could be argued that "there are insufficient grounds for it to be
pursued and its purpose is solely to annoy those affected".
With the exception of the above I agree with Ian - a valid SAR needs no
grounds.
Regards,
Graham
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