I would have thought that the member would be well within his rights to
complain about it being handled in the way suggested unless it were
necessary to do so (i.e. if Member Relations don't need to know about it
in order to process the SAR then they shouldn't get involved).
Similarly, the subject can be asked their reasons, but they are under no
obligation to give their reasons. They can, of course, complain that
they were even asked !
On the whole it is simpler just to get on with it and satisfy the SAR...
Donald Henderson
Information Compliance Manager
Perth & Kinross Council
-----Original Message-----
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Hodgetts, Jonathan
Sent: 12 July 2005 11:49
To: [log in to unmask]
Subject: [data-protection] Handling a SAR outside the Act
Sensitivity: Confidential
My company has received our first ever formal subject access request
under the Data Protection Act (aren't we lucky!). We are a membership
organisation, and the SAR is from one of our members. I want to handle
this myself fully in line with the Act, but one of our directors wishes
me to hand this over to our Member Relations department, to contact the
member to find out the reason for the SAR and handle outside the Act.
I am rather uneasy with this approach and would be grateful for views
from those on this discussion group more familiar with the handling of
SARs.
Thank you.
Jonathan Hodgetts
MCPS-PRS Alliance
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