Data Protection Update

November 26th 2019

Accountability Toolkit

The General Data Protection Regulation [GDPR] introduced an accountability principle so data controllers are required to handle personal data appropriately and effectively and are able to show this through their practices and procedures. The Information Commissioner’s Office (ICO) has announced that it intends to launch an accountability toolkit in 2020 to help organisations comply with this accountability principle.

The toolkit is to help show the ICO’s expectations as a reference point.

The ICO is currently consulting on its proposed toolkit. This is due to close on 9 December 2019. Please see following link for more details:

Subject Access Requests

Earlier this year, new guidance was published by the ICO which impacts on the timescales for responding to employees’ subject access requests. The clock starts running from day 1 (i.e. the day the request is received). It was previously thought that the one month started from the day after receipt. Employers should update their policies in line with the new guidance.

Please see link to guidance below:

Although the basic rule is to respond within one month of receipt of a subject access request, this can be extended by up to two months where necessary, depending on the complexity and number of requests. Any extension must be communicated to the employee within the initial one month together with reasons for the extension.

Don’t get caught out!

Get in touch:

If you would like more information or advice, get in touch with Philomena Price, Director and Employment Law Solicitor on 01295 204147 or you can send an email to

*Disclaimer: While everything has been done to ensure the accuracy of the contents of this article, it is a general guide only. It is not comprehensive and does not constitute legal advice. Specific legal advice should be sought in relation to the particular facts of a given situation.