If it has no discernible structure it cannot be a useful filing system -
it's a heap of paper. Bin it. It could have an internal structure (e.g.
date order) which renders it useful as a filing system, but which does not
make any one person's data readily accessible - outside the Act. If it has
an internal structure and you can find all the papers about one person with
reasonable effort - within the Act.
NB The attempt in the House of Lords to define what constitutes a structured
filing system was never accepted by the OIC, so play safe if in doubt.
regards
Su
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