Is personal data held on a workplace messenger disclosable under a SAR for an ex-employee?

Posted in : First Tuesday Q&A NI on 6 August 2019
Johanna Cunningham
Arthur Cox

Article 15 of the GDPR, gives data subjects the right to access personal data held about them by a data controller, usually via a subject access request (“SAR”).

Messages sent via a workplace messenger which involve the data subject would likely have to be disclosed as part of a subject access request if they do more than simply identify the requestor.

ICO guidance provides that for information about an individual to constitute personal data, it must go beyond simply identifying the individual and actually “concern the individual in some way”.  For example, messages sent by or to the

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Back to Q&A's This article is correct at 06/08/2019

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Johanna Cunningham
Arthur Cox

The main content of this article was provided by Johanna Cunningham. Contact telephone number is Johanna Cunningham or email

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