I'd suggest asking the HR Director whether they accept that by using someone's initials they are still processing that person's personal data, and that as a matter of fundamental law, the person has a right of access to that data (subject to the application of exemptions).

The question of how to search for that data, and the extent of "reasonable searches" is surely a secondary one?

Sent with Proton Mail secure email.

------- Original Message -------
On Tuesday, June 20th, 2023 at 10:15, Luke Thompson <[log in to unmask]> wrote:

Good morning all,

Our director of HR has seemed surprised that he cannot talk about staff using initials without this being disclosed.
My understanding is that, in certain circumstances, if the request is refined enough, initials are a valid search term for individuals and that staff who communicate using initials could reasonably be expected to have their emails disclosed.
Does everybody else consider initials as a valid search term?

Luke

--
Luke Thompson
Head of Data Protection & Legal Services
The University of Sheffield
First Floor
Arts Tower
12 Bolsover Street
Sheffield
S3 7NA

Tel: +44 0114 22 21117
Mobile: 07596550031

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