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Subject Access Request Policy

Importance of Policies and Processes

Record Keeping: Having policies and written processes in place aids in handling subject access requests (SARs).

Employee Awareness: Ensure all employees are trained to recognize SARs and report them promptly to the relevant department.

Handling SARs

Request Fulfilment: Individuals have the right to confirmation of data processing and a copy of their data, along with any supplementary information.

Request Logging: Maintain a log of all SARs, especially verbal or in-person requests, including the data requested.

Verification: If unsure of the requester's identity, ask for necessary information to confirm their identity, but avoid unnecessary delays.

Response Procedures

Response Time: Respond to SARs within one calendar month; many organizations aim to respond within 28 days to ensure compliance regardless of the month's length.

Fee Policy: Do not charge a fee for responding to SARs unless justified as a reasonable administrative cost.

Refusal or Delay: Refrain from refusing or delaying SARs unless they are repeated, manifestly unfounded, or excessive.

Communication with Data Subjects

Informing Data Subjects: Notify data subjects of any decision to charge a fee, refuse, or delay their SAR, and inform them of their right to lodge a complaint with the ICO.