As a local authority our (paper - please ignore electronic records in the context of this question) social work files are clearly accessible records under Schedule 12 DPA.
Suppose we have a file on Mrs Jones - a client for many years, so the file runs to 100's if not 1000's of pages. Mr Smith thinks he may have been mentioned in the file some years ago as he recalls speaking to Mrs Jones social worker.
Mr Smith makes a SAR for his "personal data" held in this file.
Q. So far as Mr Smith's request is concerned is Mrs Jones file an accessible record ? It seems to me that on a strict reading of the Act the answer must be yes, as the definition is not linked to the primary data subject.
This is important as it seems we must spend many hours trawling through the file - on the off chance it may have some record of Mr Smith, which when we find it may or may not be personal data (Durant).
If it is not part of an accessible record, it is only data under the extended paragraph (e) of s1 and we can use the costs exemption in s9A as it is clearly neither automatic processing data nor part of a relevant filing system.
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