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In addition to the point James raises, if you deal with it strictly as a SAR there will most likely be a large number of emails which are not the PD of the requester at all (other than his / her name) as the content will be about work issues and not about the data subject.

 

----- Original Message -----

From: James Walkom

Sent: 03/31/14 10:19 AM

To: [log in to unmask]

Subject: Re: [data-protection] Access to email account

 

Hi Matt,

 

 

 

 

 

If it is a SAR then you have to comply with it but I would be hesitant about giving access to all e-mails between a set period as the individual is no longer an employee and (depending on what their job was) there could be the personal data of 3rd parties contained in them – or at least commercially sensitive information – and this could result in a breach of the DPA.

 

 

 

 

 

You don’t have to provide a copy of the actual e-mails so I would consider extracting their personal information and provide a hard copy of this. As a minimum, I would ensure the e-mails are reviewed beforehand and anything that isn’t their personal data, redacted

 

 

 

 

 

James

 

 

 

 

 

 

 

 

 

 

 

James Walkom   
Regulatory Consultant
Jelf
Tel: 01454 525182   

 

 

 

 

 

Insurance | Employee Benefits | Financial Planning

 

 

 

 

 

Jelf
Hillside Court, Bowling Hill, Chipping Sodbury, BS37 6JX    Tel: 01454 272727    Fax: 01454 272728

 

 

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From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Matt Morrison
Sent: 31 March 2014 09:55
To: [log in to unmask]
Subject: [data-protection] Access to email account

 

 

 

 

 

Hi all

 

 

 

 

 

Monday morning question here.

 

 

 

 

 

We have received a request from a former member of staff for access to the emails held in their account between a set period (we still hold the emails). I don't know all the circumstances of the request, but suspect it may be related to an HR issue. 

 

 

 

 

 

The request has been made as a SAR and I am wondering if others have dealt with something similar and, if so, did you deal with it as a SAR? Are emails sent in a work capacity a number of months ago personal data? I suspect they may well be, depending on the content. 

 

 

 

 

 

We do also have an authorisation procedure for allowing access to email accounts in appropriate circumstances (this could even be supervised access).

 

 

 

 

 

Any thoughts welcome!

 

 

 

 

 

Best wishes

 

 

 

 

 

Matt Morrison

 

 

 

 

 

Information Rights Officer

 

 

University of Bristol

 

 

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