SAR redaction software

[networkmangler]

We have had our first SAR and it's a biggy.

 

We use Office 365 so I have used eDiscovery to search our online resources and it came back with 100,000 items!

 

We have asked for a bit of clarification to try to reduce this if possible i.e. don't include emails sent/received from requester (They should already have these), don't include emails sent/received by SAR student (again they should already have these)

 

So I am looking for some software to do the redaction and if possible has an element of automation

 

I have looked at Egress Respond, it's a little expensive and I have been told it will take a little while to setup

 

What does everyone else use? has anyone got any recommendations?

 

If possible I'm looking for software that can do files and emails. Also if anyone has recommendations on a physical redaction pen for printed documents I would b interested, we tried a permanent maker but it didn't work

[p858snake]

If you end up in PDFs, I use Kofax (nee Nuance) Power PDF for redacting PDFs for our finance system (we can't show client names), has same handy tools like Search and Redact.

[gh5000]

It was a bit of a sledgehammer approach but if you have access to Acrobat you can do pdf redaction based on a word list. So we exported names from SIMS and gave acrobat a txt file and it provisionally redacted those names.

 

We were in a similar situation in terms of size of SAR so we took the automated approach mostly. We inevitably had false positives - student name June would redact the month for example. But would rather have them come back and ask for a section to be unredacted.

 

You can say that you will respond within 3 months due to the size of the request. The acrobat redaction does take some time. I had 5 laptops running it at most times.

[psydii]

The redaction tools in advanced ediscovery now work well for us last time we had to do this.

 

Acrobat Pro for everything else.

 

We've done this four times now, the first few using Acrobat only. Running the process through advanced eDiscovery this last time saved us *weeks* of work.

[enjay]

We inevitably had false positives - student name June would redact the month for example. But would rather have them come back and ask for a section to be unredacted.

 

That isn't just about someone asking you to unredact a section, though. "The child XXXX first bulled my son on the 7th XXXX" - this tells you you're looking for a child with the same name as a month, which I think is three names and therefore enough to identify the child in question, indeed since you would know when the bullying started, you're almost certainly down to one child.

[enjay]

We have had our first SAR and it's a biggy.

 

We use Office 365 so I have used eDiscovery to search our online resources and it came back with 100,000 items!

 

We have asked for a bit of clarification to try to reduce this if possible i.e. don't include emails sent/received from requester (They should already have these), don't include emails sent/received by SAR student (again they should already have these)

 

Other than just limiting information they already have, I would suggest going further and trying to narrow down the scope to what they're actually looking for. Unless they're just out to make trouble for you, they don't actually want 100,000 items because they wouldn't be able to read them all once you've redacted and sent them anyway. Ask what event/situation/incident/person they're actually interested in, and go from there.

[David44]

That isn't just about someone asking you to unredact a section, though. "The child XXXX first bulled my son on the 7th XXXX" - this tells you you're looking for a child with the same name as a month, which I think is three names and therefore enough to identify the child in question, indeed since you would know when the bullying started, you're almost certainly down to one child.

 

Not sure it reveals anything other than that the school likely has a student named April, May, June or, at a push, August on roll. It doesn't tell you that the child involved in the bullying had one of those names though.

 

For those of you exporting a list of student names from SIMS, how do you deal with the fact that students may have left since the documents that you are redacting was written? Not to mention staff who write emails with child's initials or even something other than their legal or preferred name. I like automation as much as the next IT professional but I'd be worried about relying on it here.

[enjay]

Not sure it reveals anything other than that the school likely has a student named April, May, June or, at a push, August on roll. It doesn't tell you that the child involved in the bullying had one of those names though.

 

That depends on the context of the other sentences in which the name is being redacted. There are not a load of children with any of those names, so if I knew a child called April/May/June/August had been involved in the incident I'm interested in, the chances are high I could work out exactly which child it was.

[gh5000]

That isn't just about someone asking you to unredact a section, though. "The child XXXX first bulled my son on the 7th XXXX" - this tells you you're looking for a child with the same name as a month, which I think is three names and therefore enough to identify the child in question, indeed since you would know when the bullying started, you're almost certainly down to one child.

 

I don't understand. The sentence could be The child Anne first bullied my son on the 7th June. Both would be redacted. All the June redaction can tell you is that at some point a name of June was in SIMS. And I don't think it tells the parent much.

 

Best thing it tells the parent is that the bullying happened in one of the three months that are typically also names.

[gh5000]

Not sure it reveals anything other than that the school likely has a student named April, May, June or, at a push, August on roll. It doesn't tell you that the child involved in the bullying had one of those names though.

 

For those of you exporting a list of student names from SIMS, how do you deal with the fact that students may have left since the documents that you are redacting was written? Not to mention staff who write emails with child's initials or even something other than their legal or preferred name. I like automation as much as the next IT professional but I'd be worried about relying on it here.

 

All the automation did was speed up the process. We didn't just automate it, and then send it. It was checked before hand.

 

And we did export all former pupils names, all staff names, and all parents names to get a pretty full list.

 

It was only relied on to speed up the process, not fully replace the human aspect.

[enjay]

I don't understand. The sentence could be The child Anne first bullied my son on the 7th June. Both would be redacted. All the June redaction can tell you is that at some point a name of June was in SIMS. And I don't think it tells the parent much.

 

Edit - ah, I get you. You're redacting all names which exist in SIMS, not just the specific names of the parties involved. I now understand!

Edited July 5, 2021 by enjay

[GrumbleDook]

The SAR is a request for personal data, not emails or other specific formats. If it is taking you that long to sift through and redact then you have a problem with emails.

 

If we are talking about bullying, safeguarding, complaints and the like ... they will already be recorded elsewhere and so provided that data is sufficient. In fact, once the information is within your behaviour/safeguarding management system, the email is no longer needed. It should be deleted from the mailboxes of those involved (if there is a need for keeping it then the email can be attached as a file to the record!) and this both reduces the duplication of where data is held and looked for on an operational basis, from a data retention basis and from the position of having to deal with SARs.

[psydii]

"should"

 

**takes a long hard look at an Exchange server full of 20 year old mailboxes**

[networkmangler]

The SAR is a request for personal data, not emails or other specific formats. If it is taking you that long to sift through and redact then you have a problem with emails.

 

If we are talking about bullying, safeguarding, complaints and the like ... they will already be recorded elsewhere and so provided that data is sufficient. In fact, once the information is within your behaviour/safeguarding management system, the email is no longer needed. It should be deleted from the mailboxes of those involved (if there is a need for keeping it then the email can be attached as a file to the record!) and this both reduces the duplication of where data is held and looked for on an operational basis, from a data retention basis and from the position of having to deal with SARs.

 

Looking at the ICO website it says "Personal data is information that relates to an identified or identifiable individual. What identifies an individual could be as simple as a name"

 

I could be wrong but I'm reading this to mean that if an email (or file) has the SAR subject's name in it, it makes them identifiable and makes it personal data

 

The request we have had is for all personal data held on the individual in all formats

 

We have emails like staff sending a list of students that are due to take an exam today and the SAR subject's name is on the list.

All the emails the student has sent/received includes their name so makes them identifiable. Some of the emails he sent are just 1 word like yes or no which seems pointless to include but seem to be covered

The student joined in Year 7 and is currently in year 11 so there are years of emails like this

[enjay]

The request we have had is for all personal data held on the individual in all formats

 

So, you need to photocopy every one of that child's exercise books too.

 

We have emails like staff sending a list of students that are due to take an exam today and the SAR subject's name is on the list.

All the emails the student has sent/received includes their name so makes them identifiable. Some of the emails he sent are just 1 word like yes or no which seems pointless to include but seem to be covered

The student joined in Year 7 and is currently in year 11 so there are years of emails like this

 

This is why I said you should go back to the requester and drill down to what they are actually hoping to find. The parent doesn't want to wade through 5 years of emails about trips, lost PE kits, etc. so do both of you a favour, and find out what the parent actually wants to see.

[psydii]

...and sometimes they refuse. I have had a very apologetic family solicitor on the phone, fully aware of what was being asked, almost *everything* had to delivered. We did get concession that administrative notes like trips lists and data that was formally stored else where (such as detention lists or circulars from the SENCO) could be excluded.

 

The thing is, any exclusions don't stop the data appearing in the ediscovery phase - you still have to review them before excluding.

 

On names appearing in documents/emails: Only the part of the document/email that discusses or pertains to the subject are required to be disclosed.