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22.11.2021

StopWatch response to 'Data: A new direction' consultation

Our response to the Department for Digital, Culture, Media & Sport's consultation 'on reforms to create an ambitious, pro-growth and innovation-friendly data protection regime that underpins the trustworthy use of data'

StopWatch's consultation response answers the following questions:

Q2.3.1. Please share your views on the extent to which organisations find subject access requests time-consuming or costly to process.

Please provide supporting evidence where possible, including:

  • What characteristics of the subject access requests might generate or elevate costs
  • Whether vexatious subject access requests and/or repeat subject access requests from the same requester play a role
  • Whether it is clear what kind of information does and does not fall within scope when responding to a subject access request

Q2.3.2. To what extent do you agree with the following statement: ‘The ‘manifestly unfounded’ threshold to refuse a subject access request is too high’?

  • Strongly agree
  • Somewhat agree
  • Neither agree nor disagree
  • Somewhat disagree
  • Strongly disagree

Please explain your answer, providing supporting evidence where possible, including on what, if any, measures would make it easier to assess an appropriate threshold.

Q2.3.3. To what extent do you agree that introducing a cost limit and amending the threshold for response, akin to the Freedom of Information regime (detailed in the section on subject access requests), would help to alleviate potential costs (time and resource) in responding to these requests?

  • Strongly agree
  • Somewhat agree
  • Neither agree nor disagree
  • Somewhat disagree
  • Strongly disagree

Please explain your answer, and provide supporting evidence where possible, including on:

  • Which safeguards should apply (such as mirroring Section 16 of the Freedom of Information Act (for public bodies) to help data subjects by providing advice and assistance to avoid discrimination)
  • What a reasonable cost limit would look like, and whether a different (ie. sliding scale) threshold depending on the size (based on number of employees and/or turnover, for example) would be advantageous

Q.2.3.4. To what extent do you agree with the following statement: ‘There is a case for re-introducing a small nominal fee for processing subject access requests (akin to the approach in the Data Protection Act 1998)’?

Q2.6.1. In your view, which, if any, of the proposals in ‘Reducing Burdens on Businesses and Delivering Better Outcomes for People’, would impact on people who identify with the protected characteristics under the Equality Act 2010 (i.e. age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation)?

StopWatch response to 'Data: A new direction' consultation

StopWatch's response to 'Data: A new direction' consultation pdf

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