Failure to comply in full with an Access Request [2007] IEDPC 13

Failure to comply in full with an Access Request [2007] IEDPC 13

Legal privilege does not apply to standard internal accident reports created by employers following workplace accidents; such reports must be disclosed to the data subject unless a valid exemption applies.

Citation
[2007] IEDPC 13
Parties
Complainant: Data Subject; Data Controller / Employer: D.
Jurisdiction
Ireland
Procedural Posture
Data Protection Complaint / Decision by Data Protection Commissioner
Outcome
Complaint upheld in part; data controller required to release Internal Accident Report with redactions for third-party data.
Legal Topics
Subject Access Request, Legal Privilege, Workplace Accident Reports, Exemptions Under Data Protection Acts

Case Brief

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Parties

Data Subject

Complainant

D.

Data Controller / Employer

Procedural Posture

Data Protection Complaint / Decision by Data Protection Commissioner

  1. 1 Whether the data controller complied fully with the subject access request within the statutory period
  2. 2 Whether legal privilege could be claimed over workplace accident reports to restrict access

Ratio Decidendi

Legal privilege does not apply to standard internal accident reports created by employers following workplace accidents; such reports must be disclosed to the data subject unless a valid exemption applies.

Court Disposition

Complaint upheld in part; data controller required to release Internal Accident Report with redactions for third-party data.

Orders

  • Data controller to release Internal Accident Report to data subject with redactions for third-party and non-personal information.