Subject Access Request Process
Template
Subject Access Request (SAR) response process
A step-by-step process for responding to a Subject Access Request under UK GDPR — within the 30-day statutory deadline.
Who it’s for: Data Protection leads and operations leads at UK businesses
How to use
Follow these steps
Log the request
Date received, requester name, contact details, what was asked for. The 30-day clock starts on receipt — including weekends.
Verify the requester''s identity
Proportionate verification — typically a copy of ID plus proof of address, or matching them against existing records. Don''t over-ask: requesting unnecessary information is itself a GDPR concern.
Define the search scope
What systems hold their data? Email, CRM, payroll, file storage, support tickets. Capture every place that needs searching.
Conduct the search
Use the requester''s name, email, phone, and any other identifiers. Save the search criteria — supervisors ask how the search was scoped.
Review for exemptions and third-party data
Some data is exempt (legal privilege, management information, references). Where another individual''s data appears, redact or ask their consent before disclosure.
Compile and deliver the response
Provide the data in a commonly-used format, with a covering letter explaining: what processing is being done, who you share data with, retention, the requester''s rights, and how to complain to the ICO.
Issue within 30 days
30 days from receipt. You can extend by up to 60 days for complex requests but must notify the requester within the first month with a reason.
Log the resolution
Date completed, what was disclosed, any redactions or exemptions applied. ICO can request this log on an investigation.
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