I'm working on refreshing our SAR guidance for staff, and I've realised (I know, I'm slow) that the new definition of personal data in the GDPR doesn't include "any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual" (Sec 1 (1) (e) DPA1998).
A question, then, for those of you who process SARs regularly - will this change the nature of SAR releases?
I have to wrestle the 'any expression of opinion' clause a lot - managers are often reluctant to release emails where they have expressed an opinion about someone, particularly where the 'someone' is not specifically identified. This could also apply to comments made by neighbours in complaints.
I would be really interested to hear what you think.
Happy New Year
Jennifer Chambers
Information Governance Manager
Southwark Council
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