应对棘手的 DSR —— 实战案例与策略.pdf

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1、War stories and strategiesDealing with Difficult DSRs Marta Dunphy-Moriel,Founder,DM LegalBryony Long,Partner,Lewis SilkinJames Leaton Gray,Director,The Privacy PracticeWELCOME AND INTRODUCTIONSAbout the requestFemale employees belief=unfairly sidelined and overlooked for promotion.Accusations of a“

2、jobs for the boys”culture.A series of emails between senior male managers that contain discriminatory remarks about her gender and age.ConsiderationsRevealing the smoking gun.Fallout/damage to reputation likely.The smoking gunAbout the requestDating platform DSAR request.Requestor is a journalist.Li

3、kelihood that the data will be used to write an article(it was).ConsiderationsLikely to involve review and redaction of a large volume of potentially sensitive data(chats).Potentially pictures involved.Mindful that every communication is likely to be published(they were,in part).Love is in the airAb

4、out the requestUnfair dismissal claim.Response largely redacted-difficult to understand both context and content.Redactions and exemptions challenged.Complaint to the ICO.ConsiderationsICO involvement likely to result in wider investigation.Data subject looking for a smoking gun.Am I over-redacting

5、to this?About the requestInternal request.Requestor has a continuing grievance with another staff member.Slack had over 1m potential entries in the period and group of employees.Little search capability.ConsiderationsBoth requestor and primary focus of SAR have rights.Given the above how should we b

6、alance their rights?Likely to involve review and redaction of a large volume of potentially sensitive data(chats).Its how big?About the requestCompany restructuring.Huge surge of DSARs.HR and legal teams struggle with:ovolume of requests,omeeting time-frames,andolocating,reviewing and redacting sens