I would say that an individual can only make one Subject Access Request at a time to an organization. Further communication regarding requests for information whilst a SAR is being processed I would argue act as clarification by the data subject as to the areas which they want searches for information to be concentrated. The onus being on the data subject to come back to you on receipt of any disclosure because you have not provided the information they thought you held. All of which is entirely reasonable.
The point being that in principle a "general SAR" should pick up all the information as a matter of course that is disclosed in a "specific SAR".
The spanner in the works would be if you charge a fee and you have received multiple fees.
Piers
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Lawrence Serewicz
Sent: 21 November 2014 12:54
To: [log in to unmask]
Subject: [data-protection] Time to appeal a request
Dear All,
An applicant makes a request in 2012. A very broad request SAR. At the same time, they make particular SAR. Discussions ensue. The result is a SAR response that covers the particular SAR.
There is no immediate evidence that the general SAR was addressed.
The applicant does not chase the broad SAR.
In the meantime, the applicant puts in other particular SARs. Responses sent.
Two years later (2014) applicant reminds council that the 2012 SAR has not been answered.
Is there a time limit for SARs? I would have thought that if the applicant had not chased it within 6 months of it going overdue, it was never logged as it was caught up in the particular SARs, but no immediate emails disclose that as some of the work was done by telephone.
What is your approach to this issue?
Thanks
Lawrence
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