From the 2010 Article 29 paper:
Recital 47 of Directive 95/46/EC clarifies that "where a
message containing personal data is transmitted by means of a telecommunications or
electronic mail service, the sole purpose of which is the transmission of such messages,
the controller in respect of the personal data contained in the message will normally be
considered to be the person from whom the message originates, rather than the person
offering the transmission services; (...) nevertheless, those offering such services will
normally be considered controllers in respect of the processing of the additional
personal data necessary for the operation of the service".
I read this as saying that you will not be obliged to disclose the mails - you are a DC. But you should formally comply with the SAR in respect of confirming you hold e.g. his name and email address for the purpose of providing an email service to the Union. Apply s7(a) (b) and (c) strictly by the book remembering you need to comply with all parts EVEN IF NOT ASKED : see R2 of The Data Protection (Subject Access) (Fees and Miscellaneous Provisions) Regulations 2000 http://www.legislation.gov.uk/uksi/2000/191/regulation/2/made
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