If we are to use Regulation 1182/71 in addition to Saturday and Sundays, I think that we would go by the FOISA public holidays plus the days that are EU public holidays that are not already included - for Maundy Thursday (9 April), Easter Monday (13 April), Labour Day (1 May) Ascension Day (21 May), the day after Ascension Day (22 May), Whit Monday (1 June), 21 July (Belgian National Holiday!), 2 November (All Soul's Day), July, 2 November and 24-31 December 2020 (Commission decision 2019/C 38/5). Pity it only counts towards the final date and not completely discounted.
Just to be clear, if we receive a subject access request at 12:00 on 28 January, the response has to be issued by 11:59 on 28 February? If we receive it at 12:00 on 29 January, we have until 11:59 on 29 February to respond. If on 31 January, 2 February?
If we receive a request at 12:00 on 27 November, the response has to go by 4 January 2021 (thanks to the EU holidays - if they still apply)?
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