Subject Access Request Templates: Legal Requirements and Format

Subject Access Requests (SARs) are key rights under data protection legislation. However, they can consume a lot of time and bring challenges, especially if your business handles large amounts of personal data about many individuals. Without the right processes and procedures to respond to SARs correctly, your company may risk mistakes that could lead to non-compliance with UK data protection law and various negative implications. Processes and documentation such as templates, policies, and training can help your business understand and deal smoothly with the SAR process, allowing your team to handle SARs efficiently and accurately. This article explores how documents such as templates can help your business streamline your response process to help you comply with mandatory legal requirements. 

Why is Advance Preparation for SARs Critical?

Under the UK GDPR rules, individuals (data subjects) have the right to ask whether your business processes their personal data, request a copy, and receive details about how you use it. 

SARs can be inherently complex, and the stakes for a recipient business are often high. Mistakes in handling SARs can lead to non-compliance, reputational damage, and regulatory scrutiny. Errors in responding to SARs can lead to complaints to the Information Commissioner’s Office (ICO) and potential penalties. 

Therefore, your business can establish transparent processes, procedures, and documentation to ensure consistency and effectiveness when managing SARs. These measures can help you avoid delays and inaccuracies, allowing your team to respond confidently within the strict one-month timeframe (unless the relevant timeframes can be lawfully extended).

How Can Your Business Effectively Manage SAR Requests?

Your business can prepare for SARs by adopting clear policies, implementing structured procedures, and providing comprehensive staff training. A detailed SAR policy can explain the steps for handling a SAR, such as verifying the requester’s identity where necessary, clarifying unclear requests, and securely providing data in the correct format.

SAR policies should address key issues such as correctly logging requests, understanding applicable exemptions and assessing third-party information to determine whether it can lawfully be disclosed. These tools can provide your business with a reliable framework for handling SARs, reducing the risk of errors and ensuring timely responses. You should also train your staff to recognise SARs in any format, as individuals may submit requests through email, verbal communication, or social media, and they could land on anyone’s desk. 

How Can Your Business Use SAR Templates to Comply With Legal Requirements?

As a best practice measure, SAR templates can help your business manage requests efficiently by standardising processes. These templates ensure consistency across your responses and provide a clear structure for collecting and delivering information during the SAR process. For instance, your business can draft template documents which you have ready to use during the SAR process. 

Standardised templates can help you in various ways, for instance:

• helping you stay on track, get the necessary information, and log requests effectively to ensure none are missed. For example, you can draft and roll out SAR template letters, which you can use to respond to SARs or request any additional required information. While it is not mandatory for a data subject to fill in your specific SAR form to submit a request (as they have the freedom to make their request in a format they choose), providing such forms can help you gather the correct information and improve accuracy and efficiency. It can also help a data subject easily submit their request if they are unsure. However, note that they are still free to submit their request in any format;
• demonstrate compliance with UK GDPR requirements by showing you have consistent processes and procedures to respond to these vital data subject rights; and
• help you record the communications you engage in with data subjects. 

GDPR Essentials Factsheet

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Records and Templates

Effective records can help you handle SARs professionally and meet your legal obligations. They can also help you save time and money. However, knowing where to start with SARs and how to respond can be challenging. 

However, ensuring that any SAR templates your business uses are correct and UK GDPR compliant is vital. Otherwise, you could risk missing key information or responding to SARs inaccurately, which could cause your business to breach UK GDPR rules. You must also complete each SAR response correctly and tailor it to the individual request – rather than rely on template responses alone. 

Key Takeaways

SAR templates can be valuable tools for complying with UK GDPR requirements. They help businesses organise processes, provide accurate responses, and demonstrate accountability. However, your company should make sure your templates are legally correct and that you tailor your responses appropriately when responding to individual subject access requests. 

If your business needs advice on handling SARs effectively, our experienced data and privacy lawyers can assist you through LegalVision’s membership service. For a low monthly fee, you will have unlimited access to our lawyers, who can answer your questions and draft or review your documents. Call us today at 0808 196 8584 or visit our membership page. 

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