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How To Redact A Subject Access Request Explained...
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just a few of our bigger clients but all shapes and sizes welcome…
Failing To Respond To A SAR Is Not An Option…
Failing to respond or provide all the requested data can be a risky business. Firstly it could lead to a deterioration between Organisation and employee. Secondly it could result in a large fine, financial penalty and or an enforcement notice. Finally it could trigger a wider investigation into a Companies data protection activates and policies by the ICO. Employers cannot afford to take subject access requests lightly.
Chances are you have had a Subject Access Request SAR and hopefully the information here will help. If not it’s really worth getting yourself prepared. Put a team and policies in place to deal with them. Keep a list of all the systems and locations where personal data is stored. Remember it is not just emails and attachments, it can be text messages, spreadsheets, internal messaging systems, management information etc. Having contacts and processes established in advance will help you respond to a SAR more efficiently.
Thoughts on how to deal with a Subject Access Request:
- Double check that the SAR has been made correctly. Your allocated time will not start running until then. If you are looking for extra time this is an area that you may be able to exploit. We advise our clients that are likely to receive multiple requests over time to streamline the process of how SAR’s are received and accepted. Don’t forget to acknowledge receipt formerly.
- Again if you are looking for time consider asking for more information. You cannot demand the individual narrows the scope of their Subject Access Request but you can ask about some areas, for example time frame or search terms. You do not have to comply with the SAR until you have received the information that you reasonably require in order to respond and locate the information sought. For example, can you identify the owners of the data and the search criteria?
- It is advisable to start dealing with a request as soon as possible, as in our experience it often takes longer than you think. Build in time for a review by you and perhaps your legal advisers, especially if there is third-party personal data which will need to be redacted. As mentioned we can help with this why not get a quote.
- Do not forget hard copy data. Again we can help with this. As a leading scanning bureau we can scan all sizes and shapes of document and provide a redacted copy. We also have a capacity to scan small or bulk volumes of documents.
- In these changing times (Brexit) it is wise to consider any cross border issues. The DPA 2018 sets out the framework for data protection law in the UK. It sits alongside the UK GDPR, and tailors how the GDPR applies in the UK. GDPR is implemented differently in each member state. There can be even greater differences between other jurisdictions, such as the US (We operate our redaction service throughout the US). If information is held in another country, you will need to consider whether it is in breach of local laws to treat data stored in that location in accordance with UK principles.
- Consider whether an exemption applies. Again this is a good reason to use a professional service such as ours. Personal data can be exempt from disclosure. For example, if the information is legally privileged. See blow for more.
- Where possible look to provide the documents electronically rather than in hard copy form, its cheaper easier to distribute and has a lower carbon footprint. Again via our redact service we can make help with this area.
THINGS prospective clients ask first…
Top Problems Solved.
“We had never heard of a Subject Access Request (SAR) & had no idea where to start!”
“We require a SAR, Subject Access Request redaction service. Our team does not have the time or expertise and previous attempts to process inhouse had not gone well.”
“We needed a solution provider capable of eliminating email duplication. Page after page repeats…”
“We’ve had a Subject Access Request but don’t know how to perform an adequate eDiscovery exercise and fully search our data.”
“We need help with areas like how to communicate with the Data Subject and how to return the data at the end of the SAR redaction process.”
“We need a SAR service provider that had a mature approach to data security with experienced security vetted staff trained in Data Protection.”
Case Study…
“We received our first Subject Access Request. Due diligence is an understandable requirement. CCS supplied reference points, detailed security, privacy policies and a signed data sharing and processing agreement.”
“CCS advised on the best ways to search data based on the scope of the Subject Access Request. These returned over 10,000 emails, attachments & documents.”
“We uploaded the search results to CCS secure, encrypted portal. A free of charge, no obligation survey of the data took place within 24 hours. A detailed report was returned with a fixed price and delivery date for us to consider.”
“Upon approval CCS made a start. After a shord period they shared some output to reassure the approach matched our expectations. The finished data was loaded back to the secure, encrypted portal within the agreed deadline.”
Why Us?
UK SAR collation & redaction market leaders. +27 Year trading history. This confirms we are able to satisfy a large number of clients over a long period of time and that we have the experience to deliver high quality on time!
Reference points on request from blue chip clients. Don’t just take our word for it! We’ll try and find a good match in terms of sector and project similarity.
Secure UK based facility here in the Peak District. All our data is processed here in the UK. We use no third parties at any stage of our service. We base our systems on ISO 27001 and can provide a copy of our security policy and privacy policies.
Confidentiality guarantee. We supply a signed data sharing and processing agreement on all projects.
Each client has an account manager and a clear plan for communication. One point of contact giving prompt responses and updates is essential for deadline work.
Every Week We Process +1 Million DSAR Documents.
As a Company we offer a fully outsourced SAR / DSAR redaction service. Sit back and leave this specialist work with us. You have your day job to do and we only need minimal input at the outset.
Our operation is 100% secure, confidential and DPA:2018 / UK GDPR compliant. We combine automated intelligent data techniques with experienced human input to deliver highly accurate results. Each SAR / DSAR gets three full read throughs by different individuals. We can scan and redact hard copy documents or work direct from digital files such as PST’s, MSG’s or PDF’s uploaded to our secure, encrypted portal.
The experienced people working on your SAR / DSAR will be trained in DPO duties, GDRP and the latest ICO guidelines. Why not leave this specialist task to the experts.
SAR Pages Considered & Redacted This Week...
Simple Process…
1. We Listen & Quote.
Our company assigns an Account Manager dedicated to your SAR. Client search results are loaded to our secure, encrypted portal. Within 24 hours we survey the data and supply a fixed price and delivery date for you to consider. 95% of our quotes move to production. We provide early-stage feedback and examples to refine the redacting brief. This builds confidence and initiates the project swiftly, the aim being to fit within your delivery deadline and leave some time to review.
2. We Apply Scope.
Moving into the production phase each project blends vital human expertise with digital efficiencies, tailored to the specifications of the redaction project. We apply the SAR scope and exclude documents that fall outside. We then deduplicate and apply redaction where necessary. For ongoing accounts, consistency is maintained with the same dedicated team allocated to that account. Your Account Manager will provide regular updates on progress, keeping you informed every step of the way.
3. We Redact & QA.
Our quality control steps are then conducted. These are unique and built on the experiences of +27 years redacting documents. We then share as a final product the working, editable PDF and a fully REDACTED version via our secure, encrypted portal. Once redacted the process can not be reversed. A single flat file is created and can not be undone in anyway. We store the data for 14 days on our system and then it is deleted in line with our data security policy.
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