Subject Access Requests and a ‘Reasonable and Proportionate Search’
Subject access requests are rising, often creating significant time and cost burdens. The Data (Use and Access) Act 2025 allows only a “reasonable and proportionate search” for personal data, but recent cases, including Ashley v HMRC (2025), show that the effort involved in reviewing and redacting data can also be considered disproportionate. Organisations may therefore argue that both the search and the review/redaction process are unreasonable when compliance would be excessively burdensome.
