Subject Access Request Procedure

Introduction

Gendered Intelligence (GI) is committed to being transparent about how we process data and meeting our obligations under the General Data Protection Regulation (GDPR). Please see the Data Protection Policy for an overview of our approach. Jay Stewart, CEO, is the Named Representative for data protection at Gendered Intelligence and should be contacted on jay.stewart@genderedintelligence.co.uk if you have any queries.

This document outlines how individuals can access their data or request changes to how we process it.

Process

Individuals have the right to make a subject access request.

When making an SAR, individuals must:

• Make the request in writing. We have created an SAR form (Appendix A) which ensures we have all the information required to process the request, but requests can be made in writing or by email if preferred. Verbal requests in person or by phone/ Skype cannot be accepted.
• Provide proof of their identity when requested. As a trans-led organisation, we are aware that identity documentation does not always match the name you are using, and we will be as sensitive as possible while fulfilling our legal obligations to keep your data secure. Please talk to the named representative for more information if you are concerned.
• Specify what they want to know about their data e.g. what categories of data are stored, how long is data stored, how to rectify or erase data, etc

To make a subject access request, the individual should send the request to jay.stewart@genderedintelligence.co.uk. The GDPR requires that responses are made within one month from the request being received, but Gendered Intelligence will aim to respond as quickly as possible.

Provided that the above conditions are met, Gendered Intelligence will confirm whether or not data is held about the individual and then provide:

• a description of the personal data, the reasons it is being processed, and whether it will be given to any other organisations or people;
• a copy of the information comprising the data. This will normally be in electronic form if the individual has made a request electronically, unless they agree otherwise); and given details of the source of the data (where this is available).

If the individual wants additional copies, Gendered Intelligence will charge a fee, which will be based on the administrative cost to Gendered Intelligence of providing the additional copies.

Exemptions

If disclosure of data in response to an SAR would result in disclosure of personal data about another individual who has not consented to this disclosure, then Gendered Intelligence will deny the SAR.

If an SAR is manifestly unfounded or excessive, Gendered Intelligence is not obliged to comply with it. Alternatively, Gendered Intelligence can agree to respond but will charge a fee, which will be based on the administrative cost of responding to the request. An SAR is likely to be manifestly unfounded or excessive where it repeats a request to which Gendered Intelligence has already responded. If an individual submits a request that is unfounded or excessive, Gendered Intelligence will notify them that this is the case and whether or not it will respond to it.

If an individual wishes to appeal against GI's refusal to provide access to data they should put their appeal in writing to the named representative within seven days of receiving the letter confirming GI's decision to refuse access. If an individual is still unhappy after this appeal, they can seek advice from the ICO (www.ico.org.uk/concerns).

Download pdf below to print out a SAR form.

Document review process
Version: 1.0
Draft approved for circulation: May 2018
Board approval due: July 2018
Review Due: July 2020