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DATA-PROTECTION  2006

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Subject:

Re: SAR ID Verification

From:

Nigel Roberts <[log in to unmask]>

Reply-To:

Nigel Roberts <[log in to unmask]>

Date:

Thu, 27 Jul 2006 12:35:16 +0100

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (152 lines)

Tim:

I usually agree with you, but I don't agree this is right. Any fool can 
make a forgery of a utility bill with a computer and a scanner.

It's all about proportionality. I would argue that it is 
disproportionate for a company to require the same documents that are 
required to open a bank account, to do an SAR on a company with which 
one has an established relationship. The fact you are writing to them 
from the address they have on file should be entirely sufficent, 
provided the results of the SAR are to be sent to the same address.

On the other hand, some SARs, perhaps for sensitive data in connection 
with (e.g.) your criminal record, if any.

For example my own rather banal criminal record consists of a guilty 
plea to a minor speeding offence and a £60 quid fine. This would 
otherwise have been dealy with by fixed penalty notice except my licence 
is issued by Guernsey, not Swansea (It is probably spent by now anyway - 
it was 4 years or more ago).

Nonethless, in order to make an SAR on sensitive data, I would think it 
entirely appropriate to be required to present myself with a passport, 
photo driving licence or birth certificate IN PERSON at my local nick.

One size does not fit all IMO


Nigel
-



Tim Trent wrote:
> I don't mean this to be a banal answer.  I fear it may sound it, for which I
> apologise.
> 
> The answer is really a question:  "If you were requesting this information,
> what documents of proof would you expect to be asked for in order to prove
> that you were entitled to receive the information?  How would you wish for
> your own identity to be protected?"
> 
> I suspect you will come down to items like a letter from a utility (but not
> mobile phone) addressed to you, a copy of a driving licence at the same
> address, etc.
> 
> Tim Trent - Consultant
> Direct: +44(0)1344 392644 Mobile:+44(0)7710 126618
> email: [log in to unmask]
> Marketing Improvement Limited, Abbey House, Grenville Place, Bracknell,
> United Kingdom, RG12 1BP
> http://www.marketingimprovement.com
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> 
> -----Original Message-----
> From: This list is for those interested in Data Protection issues
> [mailto:[log in to unmask]] On Behalf Of Preston, Catherine
> Sent: 27 July 2006 12:41
> To: [log in to unmask]
> Subject: [data-protection] SAR ID Verification
> 
> Hi everyone.
> 
> If someone makes a subject access request to you, what verification
> documents do you ask for to identify the data subject. If you ask for
> official documents (i.e. passport/driving licence etc) do you accept
> photocopies being submitted or only the original? Or do you just accept the
> name and address on the letter? 
> 
> Many Thanks
> Catherine
> 
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