Responding to UK DSARs involving third-party data: UK GDPR/DPA 2018 exemption, consent, confidentiality, reasonableness, redaction and neither confirm nor deny

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Practice notes

This Practice Note is aimed at general commercial organisations in the UK. It offers guidance on handling data subject access requests (DSARs) that could require sharing material that identifies other individuals. It reflects the UK General Data Protection Regulation (UK GDPR) and ICO guidance on the right of access. This Practice Note does not address processing for law enforcement purposes or the intelligence services. There is a separate Practice Note covering other third party rights, including trade secrets and intellectual property—see Practice Note: Responding to a data subject access request—protecting third party rights.

The right of access

The right of access is one of the data subject rights set out in the UK GDPR. DSARs are relatively frequent and are regarded as the gateway right, enabling individuals to use other rights such as rectification or erasure. They can be particularly burdensome for businesses. Under the right of access, data subjects are entitled to:

confirmation of whether their personal data is processed
access to the personal data being processed
receipt of further details, broadly in line with what must be supplied in your privacy notice
a copy of

...

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Web page updated on 21/05/2026

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