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If the data hasn’t changed, including no new opinions stated about the DS, then I would say not less than three months (so they would be outside that and it would be reasonable).  However, I would be inclined to reply that there had been no change to the data processed since dd/mm/yyyy being the date on which the SAR datawas extracted, which was supplied to you on dd/mm/yyyy.

 

One of my clients is dealing with the fifth SAR from an ex-employee which arrive some days after the DS has received the supply for the previous SAR.  The point here being that the data is ‘changing’ as the case continues.  On that basis, I have advised against pushing back.

 

M

 

From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Cotterill, Steve
Sent: 23 October 2015 14:07
To: [log in to unmask]
Subject: [data-protection] Repeat SAR Requests

 

We have received a SAR from as ex-employee requesting copies of emails.

 

We have already provided the data subject with hard copies of these emails (they picked them up in person), four months ago. They have now requested them again.

 

Is this deemed as a reasonable time period between requests? The data requested has not changed. I know the ICO states requests can be made at ‘reasonable intervals’ but I am not sure what this means.

 

If I refuse to supply how would I word any such “I won’t disclose again because” paragraph’?

 

Any comments appreciated.

 

Thanks.

Steve

________________________________________________________________________________________________________________________________________

Stephen Cotterill
Procurement & Technical Officer

 


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