Data Subject Access Requests: Your Complete Guide

6 min read

Data subject access requests are reshaping how organizations handle personal information. As privacy regulations expand globally, businesses face a mounting wave of requests from individuals seeking control over their data—and the numbers tell a compelling story.

GDPR average requests increased from 5.7 in 2021 to 7.3 in 2024, while 36 percent of internet users worldwide stated having exercised their right of Data Subject Access Requests (DSAR) in 2024, up from 24 percent in 2022. This surge reflects growing awareness of privacy rights—and underscores the urgent need for robust compliance processes.

What Is a Data Subject Access Request?

A data subject access request (DSAR) is a formal inquiry from an individual to an organization, asking for access to their personal data. Under regulations like the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), these requests grant people the right to understand what information companies hold about them, how it's used, and who it's shared with.

But DSARs extend beyond simple access. They empower individuals to rectify inaccuracies, request deletion, restrict processing, or object to certain uses of their data. Think of it as a transparency mechanism that forces organizations to open their data vaults and account for their practices.

Why DSARs Matter for Your Business

DSARs aren't just legal formalities—they're trust-building opportunities. When handled properly, they demonstrate your commitment to privacy and strengthen customer relationships. When mishandled, they expose you to regulatory penalties, reputational damage, and potential litigation.

The stakes are particularly high because 66.8% of DSAR requests are made by employees, often during workplace disputes. These requests can uncover performance reviews, internal communications, and other sensitive materials that may be used in tribunal or court proceedings.

Understanding GDPR Compliance Requirements

The GDPR sets the gold standard for DSAR compliance. Organizations must respond within strict timeframes and provide comprehensive information without charging fees in most cases.

Response Timeframes You Must Know

Under the GDPR, organisations are generally required to respond to DSARs within one month of receipt. However, this timeframe can be extended by an additional two months in complex cases, taking into account the complexity and number of requests.

In contrast, the CCPA allows organizations 45 days to respond to DSARs, with the possibility of an additional 45-day extension. Understanding which regulation applies to your business is crucial—you may need to comply with multiple frameworks simultaneously if you operate across jurisdictions.

What Information Must You Provide?

When responding to a DSAR, you must deliver far more than a simple data dump. The requester is entitled to:

This comprehensive disclosure requirement means you need excellent data governance. You can't provide what you can't find, and on average, it takes around two weeks to respond to a DSAR, depending on your data infrastructure and organizational readiness.

Building an Effective DSAR Process

The difference between compliance and crisis often comes down to preparation. Here's how to build a process that works.

Step 1: Create Clear Submission Channels

Individuals can submit DSARs through any communication channel—email, social media, phone calls, or written mail. This flexibility for requesters means complexity for you. Establish dedicated submission channels and train your entire organization to recognize and route DSARs properly.

Consider implementing a web-based DSAR form that guides requesters through the process while capturing essential information you'll need for verification and fulfillment.

Step 2: Verify Identity Without Overreach

Identity verification is critical—you cannot disclose personal data to unauthorized individuals. However, you must balance security with data minimization principles. Use information you already possess rather than collecting new documents unnecessarily.

Acceptable verification methods include requiring individuals to log into existing accounts, respond from registered email addresses, or provide limited identifiers like account numbers. Avoid requesting excessive documentation like passport copies unless the risk warrants it.

Step 3: Locate Data Across Your Ecosystem

This is where many organizations struggle. Personal data rarely lives in one convenient location—it's scattered across CRM systems, email servers, backup archives, third-party processors, and legacy systems.

Conduct thorough data mapping exercises before you receive DSARs, not after. Document where different types of personal data reside, how long it's retained, and who has access. This preparation dramatically reduces response times and ensures completeness.

Step 4: Review and Redact Appropriately

Before releasing information, carefully review it to protect third-party rights and proprietary information. You may need to redact names, contact details, or other information about individuals who aren't the requester.

This review process can be time-consuming, particularly with large data volumes, but it's essential for compliance. Allocate sufficient resources and ensure reviewers understand both legal requirements and practical limitations.

Step 5: Respond Clearly and Completely

Deliver your response in a format that's accessible, concise, and easy to understand. Use plain language rather than technical jargon. Provide information electronically unless the requester specifically asks for a different format.

Include clear explanations of the data provided, your legal basis for processing, and information about the individual's additional rights (such as rectification, erasure, or objection).

Common Challenges and Practical Solutions

Research reveals that 41% of DPOs thought that data protection regulations compliance was the biggest perceived DSAR response challenge. Let's address the most common obstacles.

Managing High Request Volumes

Some organizations receive hundreds of DSARs weekly. Manual processing simply doesn't scale. Consider DSAR automation software that can streamline intake, routing, tracking, and response generation while maintaining compliance.

Dealing with Complex Data Environments

When personal data sprawls across multiple systems—particularly with cloud services and third-party processors—fulfillment becomes exponentially more difficult. Implement centralized data governance and establish clear protocols with vendors regarding DSAR assistance.

Handling Excessive or Unfounded Requests

The law permits you to refuse or charge reasonable fees for requests that are manifestly unfounded or excessive. However, the burden of proof lies with you to demonstrate why a request meets these criteria. Document your reasoning carefully and be prepared to defend your decision to supervisory authorities.

Protecting Against Data Breaches During Fulfillment

Ironically, 87.4% of DPOs' responses on social media indicated that data breaches were the biggest risk arising from DSAR requests. When you compile comprehensive personal data for disclosure, you create a high-value target.

Use encrypted transmission methods, secure portals with time-limited access, and multi-factor authentication. Never send sensitive personal data via unencrypted email.

The Cost of Non-Compliance

Failing to properly handle DSARs exposes your organization to significant consequences. Under GDPR, less severe infringements resulting in a fine of up to 10 million euros or 2% of the firm's worldwide annual revenue, whichever amount is greater.

Beyond financial penalties, consider the reputational damage, loss of customer trust, and potential for civil litigation. In contrast, organizations that handle DSARs efficiently often find they've built stronger data governance practices that benefit the entire business.

Best Practices for Long-Term Success

Transform DSAR compliance from a burden into a competitive advantage by adopting these strategies:

Looking Ahead: The Future of DSARs

The trajectory is clear: DSAR volumes will continue rising as privacy awareness grows and regulations expand. New state privacy laws in Virginia, Colorado, Connecticut, and other jurisdictions create additional compliance complexity.

Organizations that view DSARs as opportunities rather than obligations will thrive in this environment. They'll build trust with customers, reduce regulatory risk, and develop data governance capabilities that drive business value.

The question isn't whether you'll receive DSARs—it's whether you'll be ready when they arrive. Start building your compliance infrastructure today, because tomorrow's request might be waiting in your inbox right now.

Taking Action on DSAR Compliance

Begin with a thorough assessment of your current capabilities. Map where personal data resides in your organization, identify gaps in your fulfillment process, and establish clear procedures before requests arrive. Consider consulting with privacy professionals to ensure your approach aligns with current regulatory expectations.

Remember, effective DSAR management isn't about perfection—it's about demonstrating good faith efforts, transparent communication, and continuous improvement. The organizations that master this balance will navigate the privacy landscape successfully while building stronger relationships with the individuals whose data they steward.