My instinctive response is under a SAR they are requesting copies of their personal data. Therefore, are the 'to' and 'from' the data subject's personal data? If no, you don’t have to disclose.
Personally, I would not argue that should be redacted if we were doing it internally, as long as it doesn’t contain the personal data of anyone else.
Sarah White
Head of Information Governance and Patient Experience
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-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Andrew Goodfellow-Swaap
Sent: 19 August 2015 09:43
To: [log in to unmask]
Subject: [data-protection] Granularity and redacting
Good morning all,
I'm looking for a selection of views on the issue of how fine grained people are when considering what information falls into an exemption.
Example - Subject has made a SAR for all information about them held as part of a record of a complaint they made. Bob is redacting a series of emails that falls in that scope and Bill is reviewing Bob's work.
Bob has redacted the entire contents of some emails under DPA Sch.7 s.10 (negotiations), but left in the header and footer, From:, To:, etc.
Bill says that the header and footer falls under the exemption as well.
I know what I think, but what are your thoughts? Also, how fine grained do you tend to go when redacting? To the email, the paragraph, the line or down to the word?
Thoughts on or off the list much appreciated, thanks.
Andrew Goodfellow-Swaap
Complaints, Mediation & Information Officer Nottinghamshire County Council
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