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When someone asks what personal data your organisation holds, asks you to correct it, or wants it erased, treat the request as a privacy-rights case—not just a support ticket. Recognise it even if it is informal, identify the law that applies, verify the requester proportionately, then assess and document each right separately. The workflow below uses UK GDPR and Information Commissioner’s Office (ICO) guidance as its main example, with California CCPA rules clearly labelled; neither jurisdiction’s rules apply universally.
First, identify the right and the law that applies
A single message can raise several distinct rights. Log each one separately: access is a request for the person’s personal data and required supplementary information; correction (called rectification under UK GDPR) concerns inaccurate or incomplete data; erasure (called deletion in California’s CCPA materials) asks for data to be removed when the applicable legal conditions are met.
Before giving a deadline or promising an outcome, establish which law governs the organisation, the person, the processing, and the request. The sources here establish UK and California examples only. They do not provide a universal rule or a complete jurisdiction comparison. Confirm applicable local law, exemptions, and time calculations with your privacy lead or local counsel.
| Point | UK GDPR / ICO example | California CCPA / CPPA example |
|---|---|---|
| Rights described in the cited guidance | Access, rectification, and erasure | Know/access, correction, and deletion |
| Ordinary response period | Access and erasure: generally within one month under current ICO guidance | Covered requests: within 45 calendar days, according to the California Privacy Protection Agency (CPPA) |
| Possible extension | For a qualifying complex request or multiple requests, up to two further months; give notice and reasons within the initial month | One additional 45-day period when necessary; provide notice and an explanation |
| Receipt confirmation | Do not infer a separate receipt-confirmation deadline from the cited UK pages | Confirm receipt of covered know, correct, and delete requests within 10 business days, according to the CPPA |
| Separate deletion mechanism | Apply UK rules and exemptions to the particular organisation and request | California’s DROP is a separate mechanism for data brokers. The CPPA says brokers must access it at least every 45 days starting August 1, 2026, subject to the statute and exceptions |
The UK periods above reflect ICO access guidance updated December 8, 2025, and its brief subject-access guide updated July 16, 2026. California’s periods reflect CPPA materials and CCPA text effective January 1, 2026; the DROP milestone began August 1, 2026. Check current rules before relying on these date-sensitive examples.
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Recognise and log the request
Do not wait for a particular form, statutory phrase, or specialist mailbox. Under ICO guidance, a person can make a subject access request (SAR) verbally or in writing without using the words “subject access request” or citing Article 15. A request to correct or erase data likewise need not arrive as a formal legal notice. Route it promptly to the people responsible for privacy requests.
At intake, record when and where the request arrived, what the person appears to be asking for, the account or relationship involved, and who owns the next action. If the message asks for access, correction, and deletion together, track each right rather than burying them in one general support case.
Verify identity and authority only as needed
First consider what the organisation already knows. A request made through a trusted, authenticated account or an established relationship may provide enough assurance. If there is genuine doubt about identity, or someone is acting for the person, ask for only the information reasonably necessary to verify identity or authority in the circumstances.
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- Do not make formal identity documents a routine prerequisite when identity is already clear.
- Keep verification material secure and use it for the relevant check in line with applicable law.
- For a representative, establish that they are authorised to act before disclosing personal data or changing records.
The ICO’s guidance, updated December 8, 2025, says to be reasonable and proportionate about what you ask for and to request formal identification documents only if necessary.
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Once the governing law is identified, calculate the deadline under that law; do not combine the start-date rules, extensions, or business-day and calendar-day counts from different regimes. For the UK example, the ICO generally gives one month for access and erasure responses. A complex request or multiple requests may permit up to two further months, but notice and reasons must be given within the initial month. The cited ICO material does not establish a separate California-style receipt-confirmation period.
For covered California CCPA requests, the CPPA describes confirmation within 10 business days and a substantive response within 45 calendar days. If more time is necessary, one additional 45-day period may be available with notice and an explanation. Do not assume that a deadline or extension described for one right, law, or jurisdiction automatically applies to another.
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Clarify scope without unnecessarily stopping work
If it is unclear what information the person means, or the request is unusually broad, ask a focused question that will help locate the relevant data. Explain what needs clarification and keep a record of the contact. Do not assume that asking a question automatically pauses all work: the ICO notes that it may often be possible to provide some information while clarification is pending. Whether clarification affects a deadline depends on the governing law and context.
Handle an access request
Search likely locations proportionately
Search the systems and records reasonably likely to contain the person’s information, including relevant communications and repositories. A reasonable and proportionate search is not permission to ignore locations likely to hold responsive data. Record what you searched and the basis for your approach.
Prepare the data and required context
Under the ICO’s UK GDPR access guidance, the response is not limited to a data dump. It includes a copy of the person’s personal data and relevant supplementary information, such as the purposes of processing, categories of data, recipients, retention information, the source when data was not collected from the person, and relevant information about automated decision-making.
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Check whether the material contains another person’s information or is subject to a relevant legal restriction or exemption before disclosing it. Provide the response in a clear, accessible, secure way. Keep a record of the searches, review, decision, and delivery.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Handle a correction request
Pin down which data the person says is inaccurate or incomplete, and why it matters for the purpose for which the organisation uses it. Consider evidence the person supplies and the reasonable steps already taken to assure accuracy. Correct inaccurate data or complete incomplete data where appropriate.
If you refuse all or part of the request, explain why and provide the applicable complaint or review route. The ICO says a UK request for rectification can be made verbally or in writing and need not cite Article 16.
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Handle an erasure request
Do not treat a request as an automatic instruction to delete everything. Assess whether a recognised ground for erasure applies and whether an exception or continuing legal obligation permits or requires retention. The result depends on the law and facts; an organisation should not promise deletion in every case.
If erasure is granted, identify the relevant live systems and recipients or processors that need to be addressed. Distinguish operational deletion from limited backup or archival treatment, and plan so erased data does not simply reappear in normal use. If you refuse all or part, tell the person what you decided, why, and how they can challenge the outcome under the applicable rules.
California’s DROP is a distinct data-broker mechanism, not a substitute for assessing an individual CCPA request. The CPPA’s guidance says data brokers must access DROP at least every 45 days starting August 1, 2026, subject to the statute and exceptions.
Close the request with a clear outcome and an audit trail
Send the outcome securely and in plain language. State what was done or why action was refused, and include any required complaint or regulator information. Record the request and receipt date, identity or authority checks, searches, clarification, any extension notice, the decision, evidence of implementation, and delivery. That record lets the organisation explain how it handled the request.
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