I spoke with the ICO Belfast office a couple of weeks ago and the ICO are still considering what a month means – not sure it will be simple as a calendar month due to bank holidays etc.

 

I expect something like 20 working days.

 

 

Thanks

 

Stephen

 

Stephen Lemon

 

Information Management and Data Services

Digital Shared Services

Enterprise Shared Services

Department of Finance

 

8th Floor

Goodwood House

Belfast

BT1 4NW

 

Direct dial - 02890894712

Network dial - 36712

Mobile - 07973469593

Email - [log in to unmask]

 

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Michael Bacon - Grimbaldus
Sent: 08 May 2017 17:05
To: [log in to unmask]
Subject: Re: [data-protection] Subject access request transition planning

 

That's my understanding.  However as far as I am aware, but I might have missed it, there is no clarity yet on what is meant by "one month". Is it a calendar month, or a lunar month, or 31 days?

 

Further, we have no indication either what constitutes "complex" or what number might be acceptable for an extension to two months.

 

Consequently, I am encouraging clients to examine their processes and to move to a 30-day supply timeframe, if they cannot already achieve that.

 

Finally (for now), the meaning of "where possible" in connection with electronic supply is unclear.  Does it take into account the practicality of sending the data and the practicality of receiving it?  For example, it may be "possible" to email out a 100MB file of CCTV video, but the DS's email provider might limit attachment sizes.

 

M


On 8 May 2017, at 16:28, Susan Graham <[log in to unmask]> wrote:

Good afternoon colleagues

 

I am reviewing our privacy notice to see what work will be needed to make it GDPR compliant.  With regard to subject access requests, my reading of the legislation is that one received on 24 May 2018 will be subject to a £10 fee and a 40 calendar day deadline, whereas one received on 25 May will involve no fee and a one month deadline.  Have I read this aright?

 

I am not so worried about the £10/not £10 situation, as with timetabling the necessary website amendments.

 

Best wishes

 

Susan Graham.

 


All archives of messages are stored permanently and are available to the world wide web community at large at http://www.jiscmail.ac.uk/lists/data-protection.html

Selected commands (the command has been filled in below in the body of the email if you are receiving emails in HTML format):

All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html and are sent in the body of an otherwise blank email to [log in to unmask]

Any queries about sending or receiving messages please send to the list owner [log in to unmask]

(Please send all commands to [log in to unmask] not the list or the moderators, and all requests for technical help to [log in to unmask], the general office helpline)



All archives of messages are stored permanently and are available to the world wide web community at large at http://www.jiscmail.ac.uk/lists/data-protection.html

Selected commands (the command has been filled in below in the body of the email if you are receiving emails in HTML format):

All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html and are sent in the body of an otherwise blank email to [log in to unmask]

Any queries about sending or receiving messages please send to the list owner [log in to unmask]

(Please send all commands to [log in to unmask] not the list or the moderators, and all requests for technical help to [log in to unmask], the general office helpline)



All archives of messages are stored permanently and are available to the world wide web community at large at http://www.jiscmail.ac.uk/lists/data-protection.html

Selected commands (the command has been filled in below in the body of the email if you are receiving emails in HTML format):

All user commands can be found at https://www.jiscmail.ac.uk/help/subscribers/subscribercommands.html and are sent in the body of an otherwise blank email to [log in to unmask]

Any queries about sending or receiving messages please send to the list owner [log in to unmask]

(Please send all commands to [log in to unmask] not the list or the moderators, and all requests for technical help to [log in to unmask], the general office helpline)