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Emile,

Look to the case law (admittedly DPA98) - specifically Ezias and Ittihadieh (para. 100 & 103).

Dan

-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Emile Douilhet
Sent: 14 October 2019 12:14
To: [log in to unmask]
Subject: Re: [data-protection] Potentially erroneous guidance by the ICO? [UNC]

Thank you very much for responses thus far. I do agree about doing a cursory look just in case, but the GDPR doesn't have provisions of a "reasonable search" for DSARs - it is all or nothing, so if we acknowledge the request, do a reasonable search, and miss something, that will be a breach - a reasonable search may be helpful in satisfying the data subject though, so I will try that. Still, the legal implications are massive if anyone, anywhere, can ask for any organisation to look through all of its files on the off chance they have their data.

Emile

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