Section 16 (other individual's data)

Read a step by step guide to applying Section 16 of the Law to respond to an individual’s ‘data subject access request’ in the specific circumstances where the information the individual is requesting includes information about other people.
Overview
This guidance is intended to help anyone who needs to respond to an individual’s ‘data subject access request’ (‘DSAR’) in the specific circumstances where the information the individual is requesting includes information about other people. In this scenario, you need to understand and apply section 16 of The Data Protection (Bailiwick of Guernsey) Law, 2017 (‘the Law’).

The role of section 16 is to ensure that you balance the rights of everyone involved, allowing you to come to a well-reasoned decision over whether to disclose or withhold the other people’s information.

It’s important to note the different terminology for the people involved:
  • the person making the DSAR is known as the ‘data subject’ or ‘the requestor’,
  • and the people who may be identified in the content the data subject has asked for are known as ‘other individuals’.
READ: How to handle someone’s ‘data subject access request’ when there is information about other individuals involved. (Section 16 of the Law)