COMPLIANCE
GDPR Data Subject Access Request (DSAR)
Handle a subject's request to access their personal data under GDPR Article 15. Full 28-day workflow from acknowledgment to closure.
Tasks in this template
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1
Acknowledge receipt of the DSAR in writing TODAY
Article 12(3): respond without undue delay and at the latest within one month. Acknowledge receipt on day 0 to start the clock explicitly.
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2
Verify the requester's identity D+1
Article 12(6): request additional information where there are reasonable doubts about identity. Do not release data before verification.
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3
Log the request in the DSAR register D+2
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4
Determine the scope of personal data held about the requester D+3
Search all controlled systems: CRM, HR, marketing, support, backups within retention, processor systems. Coordinate with IT and system owners.
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5
Consult IT on technical data retrieval D+5
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6
Check third-party and other data subjects' rights before disclosure D+7
Article 15(4): the right to obtain a copy must not adversely affect the rights and freedoms of others. Redact third-party personal data where necessary.
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7
Redact third-party personal data from the response package D+10
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8
Compile the response: data, categories, recipients, retention, sources, rights D+14
Article 15(1)(a)–(h): include purposes of processing, categories of data, recipients, retention period, existence of rights, source if not collected from the subject, automated decision-making logic.
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9
Submit the draft response for legal review D+18
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10
Quality check: completeness, redactions, format accessibility D+21
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11
Send the response via a secure channel D+25
Article 12(3): must be delivered within one month of receipt. Use encrypted email, secure portal, or registered post per requester's preference.
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12
Update the Article 30 records of processing activities D+26
Document the request and response in the RoPA for audit and accountability (Art. 5(2), 30).
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13
Archive evidence of the request, response, and delivery proof D+27
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14
Close the request and capture lessons learned D+28