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Data Privacy Learning & Guidance

Our mission is to make data protection easy: easy to understand and easy to do. Our weekly podcasts are available in our Resource Centre along with a collection of articles, white papers, useful guidance, templates, case law, and opinions – providing you with tools you can utilise in your workplace.

Why Is Dedicated Data Protection Compliance Software Important?

Dedicated data protection compliance software is important because it reduces the reliance on cumbersome manual processes. Instead of relying on static documentation like spreadsheets, automated platforms allow organisations to maintain ongoing compliance simply and easily.

TL;DR

  • Dedicated data protection compliance software centralises GDPR compliance, rather than relying on various spreadsheets.
  • It automates processes and minimises human error, reducing risk.
  • It provides audit-ready evidence of compliance.
  • Platforms like Data Protection People’s Datawise support ongoing compliance, rather than one-off snapshots.

What is Dedicated Data Protection Compliance Software?

Dedicated data protection compliance software is a centralised platform designed to help businesses comply with GDPR. Often referred to as Privacy Information Management Systems (PIMS), it streamlines SARs, RoPAs and DPIAs, as well as training records, risk registers and more.

Datawise is Data Protection People’s compliance software, helping DPOs stay on top of everything they need to stay GDPR compliant.

Why is Dedicated Data Protection Software Important for GDPR Compliance?

Dedicated compliance software is important because it makes demonstrating accountability (an integral part of GDPR compliance) much simpler.

Centralises Compliance Activities

With one system for data mapping, risk tracking and incident management, a centralised platform eliminates fragmented processes.

Provides Evidence of Compliance

GDPR requires you to provide evidence of compliance, not just policies. Gathering this evidence can take hundreds of hours, depending on how big the organisation is. Dedicated privacy compliance software streamlines this task.

Reduces Human Error

Compliance software removes reliance on spreadsheets and standardises workflows, helping to reduce the risk of human error.

What Features Should Dedicated Data Protection Compliance Software Have?

The most effective GDPR compliance software includes tools that support everyday compliance and long-term governance. The features that should be included are:

  • Rights request management
  • Records of Processing Activities (RoPAs) management with audit trails
  • Data Protection Impact Assessments (DPIAs) workflows
  • Incident and breach tracking
  • Risk registers and reporting dashboards
  • Supplier/ processor management

How is Dedicated Compliance Software Different from General Data Management Tools?

A dedicated compliance platform is built around specific regulatory requirements, going above and beyond a simple data storage tool. Software like Datawise manages compliance processes from end-to-end, automating workflows and centralising everything you need to be compliant in one place.

Do You Need Dedicated Compliance Software to Manage a GDPR Audit?

Dedicated data protection compliance software is not a legal requirement, but it significantly improves the efficiency and accuracy of GDPR audits. It makes evidence gathering faster, audits easier and gives you better visibility of your organisation’s risk factors.

Make GDPR Compliance Simpler With Datawise from Data Protection People

Datawise is Data Protection People’s proprietary compliance software. It’s built on a world-class platform, enabling easier compliance management by centralising and streamlining data management. Get in touch to find out more.

FAQs

What is GDPR compliance software?

Data protection compliance software is a tool designed to help organisations manage GDPR obligations, including SARs, DPIAs and data records.

Can I manage GDPR compliance without dedicated software?

Yes, you can, but using manual tools is inefficient, and can lead to inaccuracies. Dedicated software centralises everything, improving ongoing GDPR compliance.

How does data protection software support audits?

Put simply, it makes demonstrating your organisation’s compliance much easier. Dedicated compliance software centralises records, provides audit trails and structured documentation.

What Happens During a GDPR Audit? A Look at Our Process

During a GDPR audit, assessors look at how your business or organisation collects, processes and protects personal data. They identify compliance gaps and risks, allowing you to meet UK GDPR requirements.

TL;DR

  • A GDPR audit assesses your data protection and risks against UK GDPR.
  • Not all audits are created equal. Data Protection People’s process prioritises real-world risks and includes a report with a prioritised action plan.
  • It helps organisations move from uncertainty to evidence-based compliance.

What is a GDPR Audit and Why Does it Matter?

A GDPR audit is a review of your business’s data protection practices, assessing whether it is GDPR compliant.

The purpose of a GDPR audit is to:

  • Identify compliance gaps
  • Reduce risk of breaches and fines
  • Demonstrate accountability

An effective audit evaluates the policies and practices of your organisation’s data handling, and helps to uncover any data exposure risks.

What Happens During a GDPR Audit?

A GDPR audit from Data Protection People always follows the same structure to ensure that we don’t miss anything.

Scope Definition

A Data Protection People GDPR audit starts with discovery. We need to understand your sector, size, data flows and key risks to ensure the audit is tailored to your business needs.

Documentation and Processes Review

We explore your existing documentation and processes, including policies, procedures, records of processing (RoPA), contracts and technical controls.

Key Stakeholder Interviews

To understand how data processing works in practice, and not just on paper, we speak to key individuals across departments.

Gap Analysis

We conduct gap analysis against UK GDPR requirements to identify areas of non-compliance or areas that are at risk of non-compliance.

Risk Priorities

Rather than a list of things that need fixing with no clear focus or urgency, we prioritise findings based on risk level, impact and likelihood, so you know what to focus on first.

Audit Report and Practical Roadmap Delivery

You receive a clear overview of your organisation’s compliance position, with the key risks highlighted.
We also provide a prioritised, actionable roadmap to bring your business closer towards full compliance.

Ongoing Support

As an optional extra, we can continue working with you to implement the recommendations, either through our support service or an outsourced DPO.

What Types of GDPR Audits Are Available?

Our GDPR audits are tailored to your organisation’s size, maturity and risk profile. The structure stays the same, but the depth, focus and outputs vary depending on the audit type. We offer:

  • Full GDPR Audit – a comprehensive review across all aspects of data handling and compliance.
  • Gap Analysis Audit – a lighter, faster health check to identify key issues.
  • Thematic / Targeted Audit – focuses on specific areas, such as SARs, DPIAs, etc.
  • Supplier/Processor Audit – assesses third-party compliance, ideal for organisations with complex supply chains.
  • Sector-Specific Audit – tailored to industries like healthcare or housing.

GDPR Audits From Data Protection People

At Data Protection People, our GDPR audits are tailored to your needs. Whether you’re a complex organisation in need of clarity or a start-up keen to get it right, we can help you focus on what actually matters.

Get in touch with our team today.

FAQs

How long does a GDPR audit take?

How long a GDPR audit takes depends on the organisation’s size and complexity, ranging from a few days to several months.

How do you know if your business needs a GDPR audit?

Your business needs a GDPR audit if you lack visibility over your data protection risks or compliance status.

Do I need dedicated software to manage a GDPR audit?

No, it’s not mandatory to have dedicated software to manage a GDPR audit. However, it does significantly improve the audit’s efficiency and accuracy.

AI and Data Protection for UK Businesses

AI and Data Protection for UK Businesses

By Amber Sivill, Junior Data Protection Consultant at Data Protection People

AI is already in the workplace, whether leadership has approved it or not. UK data shows business use is rising, with 26% of businesses reporting use of at least one AI technology in March 2026, while nearly half of employers who use or plan to use AI expect their business model to use or rely on it within three to five years. At the same time, wider workplace research suggests many employees are using their own tools without formal approval. For SMEs, that creates a familiar problem in a new form, productivity pressure on one side, data protection and cyber risk on the other.

From Data Protection People’s perspective, the answer is not a blanket ban, but instead the controlled adoption and oversight of AI tools. The Information Commissioner’s Office is clear that there is no AI exemption to data protection law, and the National Cyber Security Centre advocates that AI systems introduce distinct security risks that must be designed for, monitored, and managed. The practical goal is to let staff use AI where the benefit is real, while keeping personal data, confidential information, and security controls intact.

Why this matters now

The real issue is not only formal AI projects, but also shadow AI. Microsoft found that 78% of AI users bring their own tools to work, which is even more common in small and medium sized companies. This is particularly problematic because a quick prompt can become a security incident if staff paste in names, emails, case notes, HR material, complaints, contracts or commercial information. Cross border processing is often missed too. If personal data is sent, or simply made accessible, to a separate organisation outside the UK, the ICO treats that as a restricted transfer under UK GDPR. In parallel, the ICO has warned that wrongly relying on generative AI outputs as factually accurate information about individuals can lead to misinformation, reputational damage and other harms to individuals.

The ICO also notes that AI models can contain personal data and may embed training data in ways that could allow retrieval or disclosure. The NCSC adds that AI systems are exposed to both familiar cyber threats and AI specific threats such as prompt injection, data poisoning, and model inversion.

Ban or controlled adoption

An overarching ban has one advantage, it is simple to implement. But it is not realistic, and it can make the risk less visible by driving AI use underground. Controlled adoption is harder, but it is normally the better fit for UK SMEs because it accepts how work is realistically happening and gives you a route to govern it.

Approach Benefits Risks When appropriate
Ban Clear message, lower immediate exposure in very high-risk areas Workarounds, shadow AI, lost productivity, weak visibility Highly sensitive processing, no approved secure tooling, active incident or regulatory concern
Controlled adoption Better visibility, practical governance, safer productivity gains, staff trust Needs policies, reviews, training, monitoring and resourcing Most SMEs, where AI is already appearing in admin, marketing, IT or drafting work

This is consistent with current evidence showing rising adoption, strong employee demand and the need for governance rather than denial.

What staff need to hear

Communication for staff has to be clearly communicated and easy to understand. Organisations should be able to tell individuals the rules of what is required, what they have to do and when to ask for guidance. That approach aligns with ICO expectations on accountability and NCSC guidance on awareness, secure use and human oversight. It is also crucial that we continue to support staff by providing quality and regular training.

Do

  • Use only approved AI tools.
  • Keep prompts generic where possible.
  • Remove personal data and confidential detail unless the tool and use case have been approved.
  • Check outputs before you use or share them.
  • Escalate if you are unsure.

Do not

  • Paste personal data, special category data, client files, HR records, passwords, source code or commercially sensitive material into public tools.
  • Treat AI output as a fact without checking it.
  • Use AI to make significant decisions about people without significant human review and approval.
  • Buy or connect new AI tools without going through the approval route.

Controls and governance

For most organisations, the right control set is straightforward: keep an AI register, publish an AI policy, set an approval workflow, run DPIAs where risk justifies it, complete supplier due diligence, assess international transfers, and apply technical controls around access, logging and data loss prevention. ICO guidance is clear that a DPIA is required where new technology use is likely to result in high risk, and if in doubt, doing one is recommended. DSIT’s AI Management Essentials also directs SMEs towards an AI system record, an accessible AI policy, impact assessment, risk assessment and communication with employees.

Suggested AI policy headings

  • Policy Statement
  • Purpose and Scope
  • Roles and Responsibilities
  • Data Protection Considerations Around AI
  • DPIAs
  • Prior Consultation
  • Privacy By Design and Default
  • Data Protection Principles
  • Rights
  • Data Processors
  • Restricted Transfers
  • Cyber Security Risks
  • Intellectual Property
  • Accuracy of Output
  • AI Dos and Don’ts

How to approve AI tools in practice

When someone in your organisation wants to use an AI tool, you do not need a complicated process, but you do need a consistent one.

Start with a simple question, will the tool involve personal data or sensitive information?

If the answer is no, carry out a basic check. Look at who provides the tool, whether it is secure, and whether it fits your business and the rules of your AI policy. If you are comfortable, you can allow a limited trial and keep it under review.

If the answer is yes, you need to slow things down and consider if the processing can comply with the UK GDPR.

  • Review how the tool uses data
  • Check where the data is stored, especially if it leaves the UK
  • Carry out a DPIA if there is any real risk
  • Review the supplier and their terms

Once that is done, decide:

  • If the risks are too high, do not use the tool or look for an alternative
  • If the risks are manageable, approve it with conditions, for example limiting what data can be used and requiring human review

After approval, the job is not finished. You should monitor how the tool is used, review it periodically, and be prepared to stop using it if risks change.

Immediate next steps

  • Identify which AI tools staff are already using.
  • Approve a short list of safer tools and incorporate this into an AI policy of approved tools.
  • Send out staff communication informing them of the organisation’s stance on the use of AI as well as rules for them to consider.
  • Add AI to your DPIA and procurement workflow.
  • Review supplier terms, retention and training arrangements.
  • Check for restricted transfers and document the outcome.
  • Train managers first, then wider staff.
  • Decide who owns AI governance internally.

These are practical first steps for SMEs and align with current ICO, NCSC and DSIT guidance.

Reasonable enforcement

You cannot police every prompt, and you do not need to. Reasonable enforcement means proportionate controls and visible accountability. Use SSO and approved tool access where you can, browser or network restrictions for clearly banned tools, logging sufficiently to investigate incidents, targeted audits in high-risk teams, and a simple route for staff to ask before using a new tool. The NCSC specifically recommends monitoring and log data that lets you audit use, investigate compromise and manage security incidents, while DSIT’s hidden AI risks work makes the same point from an organisational angle, successful AI governance is cultural as well as technical.

How Data Protection People supports clients

At Data Protection People, we are seeing AI move from a side conversation to a core compliance issue. We support clients with practical AI guidance, policy and framework design, DPIA and international transfer support, contract and supplier review, documentation templates, training and ongoing advisory support through our consultancy, toolkit and support services. Our wider view is simple, organisations should protect themselves first, but they should not pretend AI is going away. The sensible path is to embrace it with caution, good governance and clear boundaries.

We will also be discussing this on the Data Protection Made Easy podcast on Friday 24 April, joined by Caine Glancy and myself, Amber Sivill. The podcast is hosted live every Friday at lunchtime and is designed for practical discussion, not theory, which is exactly what this topic needs. If you are reading this after 24 April 2026, you will be able to listen to the full discussion via Spotify. Click here to listen to the Data Protection Made Easy podcast.

Key references

How SMEs Can Handle Subject Access Requests (SARs) Effectively

Under UK GDPR, individuals have the right to request access to the personal data an organisation holds about them. Known as Subject Access Requests (SARs), these requests must be responded to within 30 days. Responding correctly requires more than simply locating and sending data. For SMEs without dedicated data protection support, SARs can be one of the most time-consuming and high-risk compliance obligations they face.

In this article, we cover why SARs are challenging for SMEs, how the right SAR support can make a difference and how data protection specialists like Data Protection People can help.

Why Are SARs Challenging for SMEs to Handle?

SARs are particularly challenging for SMEs without a dedicated data protection team for several reasons:

  • Limited resources mean handling a SAR can be time-consuming, requiring significant staff effort to locate and review data, especially when it’s spread across multiple systems.
  • Understanding what falls within scope can be challenging, especially when requests are broad or unclear.
  • Applying appropriate redactions to protect third-party rights while providing a complete response requires careful consideration.
  • Many SMEs lack standard procedures or templates for handling SARs, leading to inconsistent and inefficient responses.

How Can SMEs Manage SARs Effectively?

Assign Responsibility and Train Staff

Designate a member of staff to manage SARs, whether an internal Data Protection Officer (DPO) or a nominated individual. Ensure employees receive SAR training so they can recognise requests and escalate them promptly.

Consider outsourcing your DPO function to data protection specialists such as Data Protection People. Our outsourced DPO service ensures you have expert support to handle SARs compliantly, along with ongoing data protection support and targeted training to help your team understand when and how to escalate requests.

Implement a Clear Procedure

A clear SAR procedure should outline how requests are received, logged, verified, tracked and closed. It should include the criteria for extensions and the escalation procedure for complex or high-volume cases.

We support SMEs by establishing these procedures, creating templates for consistency and advising on data mapping strategies to locate information efficiently. This transforms SAR handling from a reactive task into a structured, repeatable workflow. We also ensure full documentation is maintained throughout, recording all actions, decisions and communications to provide a complete audit trail.

Define the Scope

Before starting any data search, it’s essential to define what the request covers and what personal data is in scope, particularly where third-party data or sensitive information is involved. This makes the process more efficient and reduces the risk of over- or under-disclosure.

At Data Protection People, we supported an organisation handling a SAR from a long-serving former employee, where the volume of emails and records raised concerns about meeting the deadline. We helped narrow the scope appropriately, clarifying that not all internal correspondence falls within scope. By helping the client interpret the scope, we significantly reduced the workload while maintaining compliance with UK GDPR.

Redact and Prepare Responses

Where third-party personal data is included, redactions must be applied with clear legal justification. Responses must be clear and GDPR-compliant, with any withheld information explained and the legal basis for withholding it explicitly stated.

These situations can be particularly challenging. For example, housing providers may receive SARs from tenants requesting CCTV footage or information relating to complaints made against them. Even where visible data is redacted, contextual elements, such as camera positioning, may still make individuals identifiable.

We support organisations in assessing whether disclosure is appropriate, advising on the limitations of redaction and ensuring the final response is compliant.

Expert SAR Support for SMEs

For SMEs without dedicated data protection resources, having the right support in place is not just a compliance measure; it’s a necessity.

If your business is struggling with SAR management or wants to implement stronger processes, get in touch to find out how Data Protection People can help.

Data Protection People Podcasts

Data Privacy Learning & Guidance

S2 Ep13: GDPR Radio: News Of The Week

S2 Ep13: GDPR Radio: News Of The Week

GDPR Radio is our regular news roundup, where we break down the biggest stories from the world of data protection, privacy, and emerging tech. In this episode, Catarina Santos and Caine Glancy walk through the latest developments in data protection, highlighting recent regulatory activity, enforcement trends, and key stories organisations need to be aware of.

These sessions are designed to give a clear, practical overview of what is happening right now, helping organisations stay informed without needing to dig through complex legal updates.

Listen back on Spotify

Episode highlights

This session focuses on recent news and real-world developments in the data protection landscape.

1) Recent data protection news and updates We cover the latest developments across GDPR and wider privacy regulation, including new guidance, legal updates, and shifts in how data protection is being applied in practice.

2) Data breaches and enforcement action The episode looks at recent breaches and fines, helping to highlight common risks and what organisations can learn from real cases.

3) Regulator decisions and trends We explore activity from regulators, including enforcement approaches and what this signals for organisations moving forward.

4) Big tech and privacy developments Discussion includes how large organisations are handling personal data, and what this means for compliance expectations across all sectors.

Key takeaways for organisations

  • Stay up to date with data protection news to understand how expectations are evolving in practice.
  • Learn from real-world breaches and enforcement action to identify and reduce your own risk areas.
  • Pay attention to regulator trends, as these often indicate where future scrutiny will be focused.
  • Ensure your organisation is adapting to changes in how personal data is being used, especially as technology continues to evolve.

Useful links

About GDPR Radio

GDPR Radio is part of the Data Protection Made Easy podcast. Join live to ask questions, share views in the chat, and keep up with what’s happening across regulation, enforcement, and practice.

Speakers

Catarina Santos, Data Protection Consultant, Data Protection People
Caine Glancy, Data Protection Consultant, Data Protection People

Weaponised SARs

What Are Weaponised SARs? Key Insights from 180 Data Protection Professionals

On Friday 10 April, the Data Protection Made Easy podcast hosted a live discussion on one of the fastest-growing challenges in information rights, weaponised Subject Access Requests, often referred to as weaponised SARs.

Led by Catarina Santos and Caine Glancy, the session attracted 180 live participants, with a highly active chat and more questions than could be answered in a single session.

This signals a clear shift. Weaponised SARs are no longer a niche issue. They are a growing operational challenge affecting organisations across housing, healthcare, local authorities and the private sector.

Subject Access Requests are increasingly being used strategically. Rather than purely supporting transparency, they are now being submitted alongside complaints, grievances, legal disputes and disrepair claims.

This does not remove the legal right of access. It does mean organisations must work harder to define scope, manage intent and respond in a way that is both compliant and proportionate.

If your organisation is already dealing with increasingly complex requests, our SAR Support Service helps teams manage Subject Access Requests efficiently and with confidence. Many organisations also benefit from wider governance support through our Data Protection Support Service and Outsourced DPO service.

Why are weaponised SARs rising?

During the session, Catarina highlighted that this trend is becoming more frequent and more disruptive.

As she explained, “Unfortunately, it’s becoming more regular and is definitely something that organisations are seeing on a very regular basis.”

The core issue is a tension between legal rights and strategic use. Individuals have a right to access their personal data, but some requests are clearly being used to apply pressure or gain leverage.

Caine reinforced this by highlighting a common pattern seen across organisations: “They only ask if they think there is a smoking gun.”

This reflects a wider shift. Many SARs are no longer exploratory, they are targeted, often driven by disputes or a belief that key evidence exists within organisational records.

The role of AI in weaponised Subject Access Requests

Artificial intelligence is accelerating this trend.

Catarina explained how AI tools are shaping behaviour: “They are relying a lot on ChatGPT and other AI platforms… SARs are something that you should always submit.”

Caine added: “Practically everybody within the meeting today has probably received a request that looks like it’s come from an AI platform.”

This creates a new challenge. Requests now often appear legally confident, broad in scope and poorly understood by the requester.

As a result, organisations are dealing not only with the initial request, but also repeated AI-generated follow-ups and challenges.

A member of the community commented, “We are seeing data subjects use AI more and more to contradict our responses. It’s becoming a real issue.”

This is one reason why having a practical SAR process matters more than ever. A clear workflow, strong template letters and the right internal escalation points can reduce risk and improve consistency. For organisations that need extra support, our SAR Support Service is designed to help with scoping, review, redaction and response management.

Real challenges shared by the data protection community

The live chat reinforced just how widespread this issue has become.

A member of the community commented, “Weaponised suits our situation. Customers will send us a SAR to delay actions or find us in the wrong.”

Another added, “Most of our requests ‘scream’ ChatGPT now.”

Another highlighted the operational frustration, commenting, “We spend so much time responding, just for it to be put back through AI and asked again in a different way.”

A recurring theme was expectation versus reality. Many requesters expect full disclosure of documents, while organisations must apply the law correctly and proportionately.

Solicitors, tone and pressure tactics in SARs

Another key discussion point was the role of solicitors and representatives.

Catarina noted that tone is often used strategically: “The tone is definitely to create fear among the people managing these requests.”

This is often combined with misunderstandings about the scope of a SAR.

A member of the community commented, “The lawyers advising them are oblivious of the fact that documents do not form part of a DSAR response.”

Another added, “Just because they ask for something, data protection still applies.”

This highlights a critical point for organisations. A SAR is a right to personal data, not a blanket right to all documents, emails or internal records.

That distinction sits at the heart of good SAR handling. It also links closely with broader compliance and governance practice, which is where services such as our Data Protection Support Service and Outsourced DPO service can help organisations build stronger foundations.

Why clarifying a SAR request is essential

One of the most important takeaways from the session was the need to clarify scope early.

Catarina advised: “Don’t be scared to clarify the request.”

Broad requests such as “all my personal data” can quickly become disproportionate if not narrowed.

She also reinforced a key legal distinction: “The right is to personal data, nothing more, nothing less.”

Clarification helps reduce unnecessary workload, focus on relevant data, improve response accuracy and manage expectations early.

A member of the community commented, “Provide everything you have on me is exhausting.”

The growing pressure on data protection teams

The discussion also highlighted the strain on internal teams.

Caine explained: “A lot of people do SARs individually… that might not be feasible anymore.”

This was strongly reflected in the chat.

A member of the community commented, “I’m just one person.”

Another added, “I have a team of 11 and it’s still not enough.”

Another said, “Many of ours are overdue as we are overwhelmed.”

This demonstrates a clear gap between legal expectations and operational reality.

Where internal resource is stretched, it often makes sense to bring in specialist support for complex or high-volume cases. Our SAR Support Service is built for exactly this, helping organisations reduce pressure on internal teams while maintaining a defensible and structured response process.

ICO guidance, challenges and uncertainty

The session also explored frustrations around regulatory guidance.

Caine said: “What would really help is more detailed guidance.”

Catarina added: “It’s too broad… it’s hard to define what it means in practice.”

The community echoed this.

A member of the community commented, “I wish the ICO would issue clear guidance from experiences like this.”

Another said, “It’s hard to know whether the ICO has received a complaint or not.”

This lack of clarity leaves organisations making difficult judgement calls without consistent, practical support.

How organisations should respond to weaponised SARs

While there is no single solution, several practical steps emerged from the discussion.

Organisations should build a practical SAR process that reflects real workflows, use clear templates for acknowledgements, clarifications and responses, clarify scope early to avoid unnecessary work, document decisions and search methodologies, and apply the law confidently and proportionately.

Caine summarised this well: “You’ve got to not be afraid to push back when things are getting too far.”

In practice, that often means having the right mix of process, confidence and support. Our SAR Support Service helps organisations manage difficult requests from initial scoping through to final response, while our Data Protection Support Service and Outsourced DPO service support wider compliance, governance and decision-making.

Why this conversation is not over, part two is coming soon

With 180 attendees and a highly engaged discussion, it became clear that one session was not enough.

Several topics require deeper exploration, including repeat SAR requests, metadata requests, grievance-led SARs, solicitor authority, search methodology and proportionality.

As Caine confirmed: “We’ll be picking apart some of these requests and taking it into a second session.”

That feels exactly right. Weaponised SARs are not a passing frustration. They reflect a broader shift in how data rights are being used, challenged and operationalised.

For anyone working in data protection, compliance, information governance or complaints handling, this is a conversation that is only becoming more important.

Need support with complex or weaponised SARs?

Weaponised SARs are not a temporary trend. They reflect a broader shift in how data rights are being used.

If your organisation is experiencing increasing SAR volumes, more complex or strategic requests, or growing pressure on internal teams, now is the time to review your approach.

Explore our SAR Support Service to see how we help organisations manage Subject Access Requests efficiently, accurately and with confidence.

You may also find it useful to explore our wider Data Protection Support Service and Outsourced DPO service for ongoing compliance support.


Frequently asked questions about weaponised SARs

What is a weaponised SAR?

A weaponised SAR is a Subject Access Request that appears to be used strategically, often alongside a complaint, grievance or dispute, rather than simply to understand how personal data is being processed.

Are weaponised SARs still valid?

Yes. A requester may still have a valid right of access even where the wider context is contentious. Organisations still need to assess the request properly, define scope and respond lawfully.

Can AI increase the number of SARs?

Yes. AI tools can make it easier for people to generate broad, legally worded requests and follow-up challenges, which can increase both the volume and complexity of SAR handling.

Do SARs give people the right to all documents?

No. A SAR is a right to personal data, not a blanket right to every document, email or report in which a person may appear.

Should organisations clarify broad SARs?

Yes. Clarifying a broad request can help narrow scope, reduce unnecessary work and ensure the response is more accurate and proportionate.

How can organisations manage complex SARs more effectively?

Organisations should use a practical SAR procedure, clear templates, documented search methods, confident decision-making and specialist support where internal capacity is limited.


GDPR Radio, S2 Ep2: Data Protection News

Grok, the Online Safety Act, and UK AI Regulation

GDPR Radio is our regular news roundup, where we break down the biggest stories from the world of data protection, privacy, and emerging tech. In this episode, Catarina Santos and Caine Glancy cover early year enforcement activity from the ICO, debate what “valid consent” really looks like in modern digital ecosystems, and explore the growing pressure on social media platforms to protect children online, including age assurance and content moderation.

Listen back on Spotify

Episode highlights

This session covers three big themes that many organisations are grappling with right now.

1) PECR enforcement is back on the agenda
We discuss recent ICO fines linked to unsolicited marketing activity and PECR compliance, including the practical lessons for opt-outs, consent language, and third-party data sources.

2) Third-party marketing lists and the “consent problem”
A key discussion point is what “informed” consent looks like when individuals are presented with long lists of third parties, and whether any approach is truly usable, granular, and easy to withdraw in practice.

3) Social media, under-16s, and age assurance
We explore the UK conversation about restricting under-16 access to social media, and the operational reality behind age verification, predictive age estimation, and the privacy and security risks that can come with them.

Key takeaways for organisations

  • If your marketing activity relies on PECR, ensure opt-out routes are clear and effortless, and your lawful basis and consent language stand up to scrutiny.
  • If you use third-party data, check what individuals were actually told, what they agreed to, and whether withdrawal can realistically be managed.
  • If you operate services used by children or young people, start stress-testing your age assurance approach now, including supplier due diligence, security, and data minimisation.
  • When new tech risks emerge, reactive fixes often fall short, governance and risk management need to be built in from day one.

Useful links

Related from Data Protection People

About GDPR Radio

GDPR Radio is part of the Data Protection Made Easy podcast. Join live to ask questions, share views in the chat, and keep up with what’s happening across regulation, enforcement, and practice.

Speakers

Catarina Santos, Data Protection Consultant, Data Protection People
Caine Glancy, Data Protection Consultant, Data Protection People

Lessons For Data Retention

Santa’s Naughty List, Lessons For Data Retention

Data Protection Made Easy Podcast, Episode 228 – Hosted by Caine Glancy and Special Guest Katerina Douni

This week’s episode takes a festive look at one of the most common challenges in data protection, knowing what to keep, what to delete, and what to safely archive. Inspired by Santa’s famous naughty list, Caine Glancy and first time guest host Katarina Douni lead a lively discussion on data retention, storage limitation, and the practical steps organisations can take to stay compliant without holding information for longer than needed.

Katarina joined the podcast for her debut session and quickly set the tone with a clear message, many organisations continue to struggle with retention. She explored why data decisions matter, how retention periods should be approached, and why email is often the biggest culprit for uncontrolled storage. The session sparked strong engagement from our live audience and the chat was filled with questions, examples, and shared challenges around retention, erasure, and day to day pressures inside busy teams.

Caine and Katarina walked listeners through common problems such as the over use of email as a filing system, storing information long after its purpose has expired, and the difficulty teams face when deciding how long is long enough. They also discussed the risks of under collecting or over collecting information, the impact this has on storage limitation, and how organisations can simplify their retention rules to reduce confusion and avoid unnecessary risk.

As always, the live chat added a valuable layer to the discussion. Attendees shared their own retention periods, debated tricky scenarios, and raised questions that pushed the session further. The interactive nature of the podcast remains one of its key strengths and gives practitioners the chance to test ideas, compare approaches, and learn from each other in real time.

This episode is ideal for anyone who handles personal data, manages email systems, or oversees compliance. It provides clear explanations, relatable examples, and practical steps that can be applied immediately. With year end approaching, the timing could not be better for organisations reviewing their retention schedules or tackling email backlogs.

If you listened back on Spotify and want to join a future episode live, you can request an invite by emailing info@dataprotectionpeople.com. Live attendees can take part in the chat, ask questions, and access the deeper insight that comes from community discussion.

We host Data Protection Made Easy every Friday at 12:30 and new listeners are always welcome. Our community continues to grow each week with hundreds joining live and many more tuning in through audio platforms.

If you work in the housing sector, you may also be interested in our upcoming in person STAIRs event taking place on the 5th of February. Details can be found on our website and on LinkedIn.

Listen below and enjoy this festive and practical dive into data retention.

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