I find it interesting and bemusing that we have some incredible challenges in the data protection world, but the thing that galvanises people into discussion is whether or not you take an extra day to answer a Subject Access Request.
I have been dealing with SARs (and FOI requests) in different roles for years and I have never received any form of query or complaint for being one day late.
If the day difference is of great importance to you, then I would suggest that your processes need reviewing. The NHS for example has an internally imposed "best practice" to respond to some requests within 20 days, any organisation for whom 31 days is an issue, I think has much larger problems to worry about.
I have found, and still find, that communication with requestors is the key. Acknowledgements and updates (where necessary) always illicit some latitude from individuals, if there are slight delays. If it's a complex request then there is the ability to extend the deadline. So I fail to see why this change by the ICO is anything other than a "take note" and change the timings in the systems, type activity.
Simon Howarth.
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