In response to a DSAR from an individual who had also brought an
employment tribunal claim, First Choice Selection Services Ltd, a
Northern Ireland employment agency, informed the individual that
they would only release the information requested when they were
instructed to do so by the tribunal.
The individual then made a complaint to the ICO which found
that, as well as failing to comply with the DSAR, First Choice was
in breach of the accountability principle – demonstrating
that their data processing activities comply with the data
protection principles.
The ICO's enforcement notice dated 2 March 2021 required
First Choice by 1 April 2021 to properly respond to the DSAR and to
make changes to their internal systems, procedures and policies to
ensure that they identify and respond to future DSARs. Failure to
comply with an enforcement notice could result in a large fine of
up to £17,500,000 or 4% of global turnover (whichever is the
higher) although there is no
