Data Protection: Subject Access Policy
About this Policy
This policy describes how Cordia (Services) LLP will ensure that subject access requests are fulfilled in compliance with the Data Protection Act 1998. It has been prepared in terms of the organisation’s obligations as a “data controller” under the Data Protection Act 1998.
It is also intended to ensure that Cordia (Services) LLP fully complies with all codes of practice on subject access requests issued by the Information Commissioner. The policy should be read alongside the organisation’s Guidelines on Subject Access Requests that give more detailed information to staff on compliance with subject access requests.
Access by Data Subjects
Under the Data Protection Act, “data subjects” have the right to see the data held on them.
Any request must be made in writing but a pro forma application form will be sent out in response to telephone queries. In order for Cordia (Services) LLP to respond to a request it must be provided with sufficient details to allow it to locate the information, together with the applicable fee and must also be satisfied as to the applicant’s identity and the authority of anyone acting on their behalf. The standard application form is designed to facilitate this process. As permitted by the relevant Regulations, Cordia (Services) LLP charges a fee of £10.00 for CCTV subject access requests. This fee is not refundable. Cordia (Services) LLP will review its policy on levying this charge on an annual basis.
Cordia (Services) LLP is entitled to refuse subject access requests in certain limited circumstances. The main circumstance is where disclosure would prejudice the prevention or detection of crime or the prosecution of offenders. In any case where data has been passed to the Police or Procurator Fiscal, any subject access request for that data will be denied until such time as Cordia (Services) LLP has been officially notified that no proceedings are to be instituted or those proceedings have been concluded. Anyone seeking access to data in such circumstances should approach the Procurator Fiscal.