How should employers deal with SARs that relate to disciplinary and grievance procedures?

Posted in : First Tuesday Q&A NI on 5 February 2019
Chris Fullerton
Arthur Cox NI
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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Back to Q&A's This article is correct at 05/02/2019

The information in this article is provided as part of Legal-Island's Employment Law Hub. We regret we are not able to respond to requests for specific legal or HR queries and recommend that professional advice is obtained before relying on information supplied anywhere within this article.

Chris Fullerton
Arthur Cox NI

The main content of this article was provided by Chris Fullerton. Contact telephone number is 028 9023 0007 or email

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