Data Protection Act 1998: Guidance for Cabinet Office Staff
Standards and Best Practice Handbook for Government Departments
9. Redacting/Extracting
Issue
Under section 7(1)(c)(i) of the DPA an individual is entitled as part of
his subject access request to:
“have communicated to him in intelligible form … the information
constituting any personal data of which that individual is the data subject
…”.
2. The right of access is therefore to the personal data, not to the
document in which the data is contained. Since usually only part of a
document will contain personal data, departments have been either providing
documents that show the relevant personal data with the remainder redacted
or blocked out, or extracting the relevant personal data and constructing a
digest of extracts. Practice varies between departments as to which method
they use.
Standards
3. Departments will decide whether to provide extracts or redacted material
in each individual instance, depending on the nature of the case. Either
approach will be acceptable.
Recommended best practice
4. While both methods of providing an applicant with personal data (ie
documents that have been redacted or extracts from documents that have been
typed out) are acceptable, the provision of personal data in the form of
extracts is often preferable in presentational terms. This is, however,
resource intensive and it will be for departments to determine which method
(or a mixture of the two) is appropriate on a case by case basis. Factors
that should be taken into account in determining the most appropriate
method include:
-
the resource and cost implications;
-
the amount of information from a document to be released, ie where one
method offers the only sensible option;
-
the option that offers the best chance of avoiding accidental disclosure
of irrelevant or exempt information; and
-
the presentational aspects of the proposed method.
5. An example of a format which some departments use for extracts is at 9A.
9A. Example of Extracts Containing Personal Data
The relevant part of a letter between officials dated 1/1/01 reads:
-
“Please provide advice for [name withheld] on (name of data subject) and
a draft reply to his letter.”
Our correspondence records show that we received 50 letters from you
between 1/1/01 and 31/12/01. We no longer retain copies of your letters or
our replies”.
The relevant part of a letter from an official to a Minister dated 1/1/01
reads:
-
“I recommend that you write to [name withheld] setting out your views on
(name of data subject).”
The relevant parts of a email between officials dated 1/1/01 reads:
-
“We have been informed that (name of data subject) has written to the
Minister . ………. and that he intends to make a formal complaint.”
Data Protection Handbook [PDF, 710KB]
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