Good morning

The applicant is entitled to data, not to copies of records. If an email is about me, the subject and quite possibly the sender are part of my data. Besides, it’s probably more effort to edit them out if you decide that they’re not my personal data. The footer isn’t my personal data. If you’re giving me the contents email anyway, there is no sense in removing the footer, especially if it’s easier just to provide a copy of the whole thing either electronically or on paper.

But if you’re using an exemption to withhold my personal data, then the header and footer are either exempt because they’re part of the data you’re withholding, or they’re not my personal data, in which case you don’t give me anything. Sending heavily redacted versions of documents isn’t good practice; it makes as much sense to give them the bits that remain, rather a sea of black boxes.

Tim Turner

On 19 August 2015 at 09:50:33, Andrew Goodfellow-Swaap ([log in to unmask]) wrote:

Good morning all,

I'm looking for a selection of views on the issue of how fine grained people are when considering what information falls into an exemption.

Example - Subject has made a SAR for all information about them held as part of a record of a complaint they made. Bob is redacting a series of emails that falls in that scope and Bill is reviewing Bob's work.

Bob has redacted the entire contents of some emails under DPA Sch.7 s.10 (negotiations), but left in the header and footer, From:, To:, etc.

Bill says that the header and footer falls under the exemption as well.

I know what I think, but what are your thoughts? Also, how fine grained do you tend to go when redacting? To the email, the paragraph, the line or down to the word?

Thoughts on or off the list much appreciated, thanks.


Andrew Goodfellow-Swaap
Complaints, Mediation & Information Officer
Nottinghamshire County Council

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