The phrase to use is "Here is all the information which you are entitled to receive under the DPA" - you dont have to explain what has been left out
or the reasons why you have left it out.
Keep records of reasons in the form of file notes saying not to disclose for whatever reason if you need to justify it at a later date.
>>> Su Goulding <[log in to unmask]> 11/14/01 04:03pm >>>
That details of access requests will be recorded is implicit in applying
S.8(3) - follow-on requests. Appropriate retention periods depend on the
nature of the data provided - e.g. marketing might need a shorter timescale
than social services.
If data has to be edited in line with exemptions and third party
restrictions prior to disclosure, it could be useful to retain a copy of any
edited material in order to ensure a) consistency of future disclosure and
b)to justify the nature of the editing in the event of a dispute.
If there is a need to gather data from various sources, the memos/e-mails
which catalogue this will need to be added to the data subject record in
order to keep it complete. One SAR was followed by a letter asking "and is
that really all you've got about me?". The honest answer was: "yes, except
for our internal communications needed to gather all the information to
fulfil your initial request. If you really want to see these, you can, but
they don't add anything to what has been provided already". Sadly, this
might get you into a never-ending loop, should you decide to play ball...
regards
Su
Su Goulding
Data Protection Analyst
tel: 020 7330 3491
mobile: 07767 674376
[log in to unmask]
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