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Anonymous
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Asked: March 30, 20212021-03-30T16:00:34+01:00 2021-03-30T16:00:34+01:00In: GDPR

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Three linked employee SARs from A, B and C. A is the Line Manager of B and C. B and C have made SARs which include messages sent in Microsoft Teams by A to designated individuals about them.
Data has been found which is the opinion of A about B and C.
It is not reasonable to ask the consent of A. A has also made a SAR which also includes comments made by B or C about them. It will be very difficult to redact the details of the recipient of A’s messages. They will know A made the statements as they specifically asked for this within the SAR. The question is whether to state they were made in confidence or disclose. I am leaning towards disclosure. Thanks

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    1. HellenB

      HellenB

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      HellenB Silver contributor
      2021-03-31T18:52:33+01:00Added an answer on March 31, 2021 at 6:52 pm

      A’s message talking about B and C and vice versa is the property of the person sending the message (despite the fact that it mentions B and C etc.) and consequently you need their consent to disclose, particularly if you can’t hide the identity of A in the message. In this instance, disclosure is not appropriate.
      If this is part of potential legal proceedings and the SAR actions of all three are part of a fishing exercise, it is important to firstly understand what is being disclosed, and to whom. Then you must get appropriate permissions. If the latter is too difficult, it is not appropriate to disclose as a default action.
      The decision to disclose or not should be taken by someone with the appropriate authority in the business, particularly if this is likely to result in a claim against the company for some form of disciplinary or legal action.

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