How should employers deal with SARs that relate to disciplinary and grievance procedures?Posted in : First Tuesday Q&A NI on 5 February 2019 Issues covered:
Subject access requests (‘SARs’) are dealt with under Article 15 of the GDPR which permits data subjects to find out if their personal data is being processed; and, if so, to obtain personal data via a SAR. However, difficulties can arise for employers when data requested contains other employees’ personal data.
In the case of a SAR relating to a grievance or disciplinary matter, it is likely that other individuals will be referred to, or even be identifiable from the information. Therefore, it is prudent for employers to consider whether any exemptions under the DPA 2018 apply which would prevent disclosure of such personal data. Although there is no specific exemption for data relating to
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