Document Management System Helps Manage Subject Access Requests

Document Management and Subject Access Requests

A Document Management System can play a crucial role in managing Subject Access Requests (SARs) efficiently, especially for organisations dealing with large volumes of personal data.

Subject Access Requests, which are incorporated in data privacy laws like GDPR (General Data Protection Regulation), allow individuals to request access to the personal data a company holds about them.

The great benefit of a document management system like Document Logstix’ Document Manager is that approved users can search for all information relating to a subject instantly, across all data formats, in a secure central store.

Document management systems significantly cut the time it takes to fulfil a SAR. You can respond within the thirty day time limit and comply not only with GDPR but also with data protection legislation such as The Data Protection Act 2018.

Addionally, built-in redaction tools enable the respondent to remove the data of people unrelated to the requestor or subject of interest. Redaction prevents data breaches that can lead to fines, a court order or reputational damage.

A document management system is essential for handling large volumes of SARs, when manually sorting paper files can become massively time consuming and manual email searching is impossible.

What is a Subject Access Request?

A Subject Access Request (SAR, sometimes DSAR) is a legal mechanism that allows individuals (referred to as “data subjects”) to request access to the personal data that an organisation holds about them. This is a key right under many data protection laws, including GDPR in the UK, European Union and similar privacy laws worldwide.

Key aspects of a SAR:

1. Right of Access:
   • Individuals have the right to know what personal data an organisation holds about them and how that data is being processed.
   • They are also entitled to know the purpose of data processing, who has access to their data and how long it will be stored.
     
     
2. Types of information that can be requested:
   • Personal data such as name, address contact details.
   • Details of how their data is being used or shared.
   • Copies of emails, files or other documentation where their personal data is mentioned.
   • Information about data retention and the source of the data.
     
     
3. Timeframe for response:
   • Under GDPR, organisations must respond to a SAR within one month from the date of the request, though this can be extended to two months for complex cases.
     
     
4. Format of response:
   • The response to a SAR should be provided in a clear and accessible format, often as a written document or electronically, especially if the request was made via digital means.
     
     
5. Exemptions:
   • Some data may be exempt from disclosure. For example, if providing the data would infringe on the rights of others, involve confidential information or affect legal proceedings, the organisation may be allowed to withhold it.
     
     
6. Fees:
   • Generally, organisations cannot charge a fee for fulfilling a SAR, although in certain cases (such as repeated or excessive requests), they may charge a reasonable fee to cover administrative costs.
     
     

Example:
If an individual believes a company is collecting or processing their personal data (e.g., for marketing or employment purposes), they can submit a SAR to request a copy of all relevant personal data held by the company, along with details on how the data is being used.

For more detailed information, you can check out:

• ICO: Information Commissioner’s Office Subject Access Request Guide
  
  

Are Subject Access Requests on the increase?

SARs are increasing primarily because people are better informed about their privacy rights. Other factors include the increased involvement of insurance and law firms submitted SARs, and employee submitted SARs during and following the pandemic.

A recent E&Y survey of customers recorded the increase in SARs statistically as:

• 60% of respondents reported an increase in SARs over the past year.
• 51% had received complaints from data subjects about SARs.
• Claims management companies make an increasing number of submissions on behalf of data subjects and are a growing source of concern for Data Protection Officers.
• 88% handle SARs in-house, mostly through dedicated data protection teams, but often splitting the work between HR, Legal, IT and Compliance.
  
  

A digital document management system facilitates SARs fulfilment

Using a document management system, SARs respondents would not have to split work between departments as data is centralised and searchable. Here’s how a DMS helps in the SARs fulfilment process:

1. Centralised data storage

A DMS ensures that all documents are stored in a central location, which makes it easier to locate the relevant data quickly. Secure document management and centralisation are crucial when responding to SARs, as they help to prevent the risks of tampering and missing critical documents. The system can track, tag and index documents based on metadata, which enables swift retrieval of personal data.

Example:
If an individual requests data related to their personal profile, the DMS allows you to search for and locate all relevant files across the organisation in seconds.

2. Automated search and retrieval

Document management systems like Document Manager come with powerful search features that can scan documents for keywords, names or other identifiable data. This functionality is key when fulfilling SARs since the organisation needs to search for all instances of a data subject’s information across multiple documents and systems.

Example:
Instead of manually sorting through files, a DMS can search all instances where a data subject’s name appears in documents, which reduces time and errors.

3. Audit trails and compliance

DMS solutions provide audit trails, which are vital for GDPR and other compliance purposes. These trails track who accessed, modified or shared a document. When handling SARs, this functionality ensures that companies can demonstrate their efforts to comply with regulations and that sensitive information is handled securely.

Example:
If you need to prove to a regulatory authority that a SAR was handled properly, the audit trail will show when the documents were accessed and by whom.

4. Access control and data security

A DMS enables you to manage permissions and ensure that only authorised personnel can access sensitive personal data. This feature is essential to prevent unauthorised access to personal information, which ensures compliance with data privacy laws.

Example:
If only the HR department is authorised to handle employee SARs, the DMS can restrict access to relevant files to ensure that only authorised staff can view them.

5. Document redaction

Most DMS platforms offer redaction tools that enable companies to remove or obscure sensitive information from documents before sharing them. Redaction helps in complying with legal obligations while protecting other individuals’ data that might appear in the same documents.

Example:
If a SAR request involves documents that also contain third-party data, a DMS can be used to redact that information before sharing the document with the requester.

6. Collaboration and workflow automation

A DMS can streamline workflows by automating the SAR handling process. It allows various departments to collaborate on the same document simultaneously while maintaining version control. Additionally, automatic reminders ensure that SARs are processed within the legally mandated timeframes (e.g., 30 days under GDPR).

Example:
If a SAR request is submitted, the DMS can automatically notify all relevant departments and assign tasks to ensure the request is handled promptly.

Conclusion: Document Management and Subject Access Requests

A DMS enhances efficiency, accuracy and compliance in handling Subject Access Requests by centralising data, automating document retrieval, maintaining audit trails and ensuring data security.

Digital document management and data centralisation significantly reduce the manual effort, time and risk associated with SAR fulfilment.

Built-in redaction tools for SARs GDPR data privacy compliance.
Example shown: personal information redacted on driver’s licence held in HR records.

Resources for more GDPR SARs handling information

Read Securiti’s review of data privacy laws around the world

An Introduction to Document Management

What is a document management system: DMS Today

Why organisations still struggle with GDPR in 2026