Clare Brennan and Catherine Gage outline key SAR changes under the new Data Act in Personnel Today
Clare and Catherine’s article was published in Personnel Today, 30 April 2026, and can be seen here.
Clare Brennan, Partner in our Corporate and Commercial department, and Catherine Gage, Associate in our Charity department, explore the growing challenges employers face when dealing with subject access requests (SARs).
These requests are increasingly being used as a tactical tool in disputes rather than purely for data transparency, placing significant pressure on HR teams to conduct extensive and complex data searches, particularly as litigation risks rise.
The article highlights how the Data (Use and Access) Act 2025 seeks to rebalance this position by equipping organisations with clearer, more practical tools. In particular, the confirmation that only “reasonable and proportionate” searches are required reduces administrative burden while maintaining compliance with data protection obligations.
Importantly, the new framework strengthens protections around third-party data and confidentiality, enabling organisations to confidently redact, anonymise or summarise information where necessary. Alongside greater procedural flexibility, these changes aim to make SARs more manageable while ensuring individuals’ data rights remain protected.
The reforms ultimately mark a shift towards a more balanced and pragmatic approach, empowering organisations to handle SARs with greater confidence while reducing the risk of misuse and preserving the fairness of internal processes.
Read the full article on the Personnel Today website, [external link].