Hi Catherine. This is a scenario that i have had to deal with a number of times in considering whether the provision of certain documentation is likely to result in unlawful disclosure of another employees personal information.
The ICO is really helpful on this point and i would suggest you read his guidance on this matter - http://www.ico.gov.uk/for_organisations/data_protection/~/media/documents/library/Data_Protection/Detailed_specialist_guides/SAR_AND_THIRD_PARTY_INFORMATION_100807.ashx
Basically he says that; Section 7(4) of the Act provides that if you cannot comply with the request without disclosing information relating to another individual who can be identified from that information, then you do not have to comply with the request unless:
• the third party has consented to the disclosure; or
• it is reasonable in all the circumstances to comply with the request without the consent of the third party individual.
To help you decide whether to disclose information relating to a third party individual, follow this three-step process.
v1.0 -
I won't detail this as it is extensive, but it certainly helps you to evaluate the situation and make an appropriate decision.
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