Priya Thapar

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Redundancies and job losses on the horizon? Make sure you are ready to handle multiple subject access requests

Big Data / 26 October 2020

The UK government is maintaining course on winding down the furlough scheme in favour of the less extensive Job Support Scheme by the end of October. Given the continued effect of the COVID-19 pandemic on the UK economy and the likelihood of increased social restrictions in the near future, it seems inevitable that, unfortunately, widespread redundancies or job losses may be forthcoming.

In our experience, when an individual’s role is made redundant of their employment is terminated for other reasons, they often resort to Article 15 GDPR to make a subject access request (“SAR”). In most cases, individuals use SARs to try and achieve a more favourable outcome for themselves (usually more money in a settlement agreement, a reconsideration of the relevant decision or documents they feel might assist their position). This is a particularly common response to being made redundant.

If you are in a position where redundancies or job losses become necessary, we recommend that you assume you will receive SARs from at least some of the affected individuals and plan accordingly. In its guidance on SARs, the ICO makes clear that it expects organisations to have a systematic procedure in place in advance of receiving SARs so that organisations can deal with them to the fullest extent of their obligations and in line with statutory timeframes. Where such a system is not in place, or is flawed, and a response to a SAR is non-compliant (for example by being late or incomplete), it is more likely that your organisation will be fined. We therefore recommend that you review your SAR response procedure and either stress-test it, or at least consider whether there is room for improvement.

In particular, it is useful to understand in which situations (i) your organisation is entitled to refuse to act on multiple or unfair SARs and (ii) your organisation is allowed to extend time for response. In circumstances where your organisational resources may be spread thinner than usual.

To talk through any of these issues get in touch with Priya Thapar on +44 (0)20 3691 2063 or email


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This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. This update relates to the prevailing circumstances at the date of its original publication and may not have been updated to reflect subsequent developments. If you have general queries about our updates, please email:

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