Is this not the classic Durant case scenario (regardless of whether you agree with that case)? The investigation is focussed on the actions of X and Y not the applicant. It is foocussed on them and so it is possible that very little of the file is the personal data of the person making the complaint unless for some reqason such as a counter accusation swings the investigation back onto the applicant.
If this is simply a case where there the complaionr is actually not involved then the only personal data regarding the complainor would be the complaint and the correspondence between the complainor and the investigator.
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