SAR and Email address redaction

[MrBitey]

Hello all,

 

We are currently compiling information for an ex-staff member SAR and have printed out large numbers of emails.

Information in the emails pertaining to other members of staff involvement in any incidents have been edited so that the names of those individuals are redacted to preserve their privacy.

 

The emails have cc and bcc information included and we are leaving this in as it just shows the individuals who were involved in any email chain discussions about the original data subject. I don't believe this is infringing on the privacy of their data.

 

I think we don't need to redact these email addresses but there is a slight niggle in the back of my mind that we might?

 

What do you think?

[sigma]

There is good advice here: https://ico.org.uk/media/for-organisations/documents/2259722/subject-access-code-of-practice.pdf

eg

As your obligation is to provide information rather than documents, you may delete names or edit documents if the third party information does not form part of the requested information.

 

This may also help : https://ico.org.uk/media/for-organisations/documents/1554/determining-what-is-personal-data.pdf

 

There area lot of guidance notes on the ICO website. Your DPO should also be able to help.

 

If in doubt, talk to the ICO on 0303 123 1113 or email [email protected]

[enjay]

I've not read Sigma's links yet, but will do so when I have a "spare" moment. That said, when we did similar recently, I think we left the names of staff members in but redacted their email addresses, and redacted names and addresses for people outside the school (parents, County, etc.)

[Opendium_Steve]

You could pseudonymise peoples' names (i.e. replace each with a unique identifier and keep hold of a spreadsheet of IDs and the associated names). That way you would be in the loop and be able to make a decision if anything needed to be deanonymised. Depends how much effort you want to go to though

[enjay]

You could pseudonymise peoples' names (i.e. replace each with a unique identifier and keep hold of a spreadsheet of IDs and the associated names). That way you would be in the loop and be able to make a decision if anything needed to be deanonymised. Depends how much effort you want to go to though

 

That would require us to be able to edit the documents which are being redacted - often, they are PDFs or text in an email chain, where all we can (easily) do is go at them with a Sharpie then re-scan.

[Areku]

I cant say officially but we took advice from our data protection team at the council, and in their words "as the ex-member of staff had privy to the information with in the emails, and would already aware of the content and contacts of those emails, theres really no need to redact that sort of information, your only protecting information the ex-member of staff wouldn't already know, about another person, but if in doubt over redact, as you can release the information if its requested"

[GrumbleDook]

I cant say officially but we took advice from our data protection team at the council, and in their words "as the ex-member of staff had privy to the information with in the emails, and would already aware of the content and contacts of those emails, theres really no need to redact that sort of information, your only protecting information the ex-member of staff wouldn't already know, about another person, but if in doubt over redact, as you can release the information if its requested"

 

The problem with that position is that you do not know who the ex-member of staff will be sharing that data with, e.g. unions, book publishers, journalists, lawyers. If they know the details and context they can fill in the blanks themselves. This is an important consideration when considering the privacy of individuals.

[gch]

If the email thread is created in PDF format, wouldn't using Acrobat pro or similar with an auto redaction tool be easier than printing them all out and using a Sharpie?

We have a request from a parent and have many thousands of emails to redact, I'm not doing that manually.

What to other people use?

[enjay]

If the email thread is created in PDF format, wouldn't using Acrobat pro or similar with an auto redaction tool be easier than printing them all out and using a Sharpie?

We have a request from a parent and have many thousands of emails to redact, I'm not doing that manually.

What to other people use?

 

I don't know Acrobat Pro very well, although we have just bought a copy for another purpose. Can the auto-redact find all email addresses, or would we have to search for specific ones?

 

As an aside, if you're having to redact "many thousands of emails", I would suggest you try and narrow the scope of their SAR. Unless they're just trying to make trouble for you, there are likely to be interested in material from a particular person or time-frame or on a particular topic. Have a conversation with them, find out why they're asking and take it from there.

[gch]

Yes, narrowing it down would be useful! I will see what they come back with.

 

Acrobat pro is good, yes. I have only tried it once, but I created one long PDF document with all the emails and using the redact tool you can filter for all email addresses and/or specific names. I was going to add all names we have in our system, staff and students, for the last few years and filter those out. It also then removes any data behind the redaction marks - just to make sure.

Only issue I have found is that it then seems to want to convert certain sections into images that are no longer searchable, preventing me from running further searches, (I don't know why it does this yet) so they still need to be manually redacted, but it's easy enough.

 

It should save many hours of work...

[PotNoodleTech]

It should save many hours of work...

 

I hope you're charging them appropriately for many hours of work by several members of staff. Remember the ICO says: "where the request is manifestly unfounded or excessive you may charge a “reasonable fee” for the administrative costs of complying with the request."

[gch]

I doubt our school will request any money from the parent, but it is a lengthy process.

 

one subject = all their emails and data, all emails and data from the entire domain that refer to or mention subject.....

 

Surely more schools are having to do this and have worked out a really good and efficient process?

There's probably a thread with lots of lovely info on here somewhere that I havn't found yet, so if anyone has seen one, please let me know.