Hi Lindsay,
I would use the ID/proof of address as confirmation that they are who they say they are, and send the results to wherever they nominate. The thinking behind this is that anyone other than the data subject would not have access to the ID. My feeling is that it would be reasonable of us to assume if we received a copy of photo ID and address ID (two different pieces) that match the records we have on file, then we can be reasonably confident that they are who they say they are.
If you are happy they are who they say they are from the ID received, they can consent to having the information they have requested sent to a different address of their choosing.
Best wishes,
Michelle
Michelle Peel
Information Manager
Transport for Greater Manchester
2 Piccadilly Place, Manchester M1 3BG
Direct line: 0161 244 1123, Extension 701123
www.tfgm.com
Please do not print this email unless you really need to.
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lindsay Foody
Sent: 10 February 2017 08:24
To: [log in to unmask]
Subject: [data-protection] SARs Made From Temporary Address Abroad
We have received an enquiry about an SAR from a resident who is currently living abroad, outside of the EEA.
They are happy to send their ID / proof of address in the Borough, by international courier and have asked for the ID to be returned to the address abroad and for the response to be sent either by email or to the address abroad.
My concern is that we have no evidence of proof of the address abroad and communication so far has been by email, so I have no way of knowing if it is the data subject who has made the request and will receive the returned ID / response. Any thoughts on this issue will be gratefully received.
Lindsay
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