03.09.2026

Our HR consultants are seeing an increase in Data Subject Access Requests (DSARs) from employees, particularly where an employment relationship has become strained or an employee feels their concerns have not been heard.

For HR teams, that can mean an already difficult employee relations issue suddenly becomes much more time-consuming.

A DSAR gives an individual the right to ask an organisation for copies of their personal data. In an employment context, that could include information held across emails, documents, meeting notes and other records.

While employees can make a DSAR at any time, our HR consultants are increasingly seeing them arise alongside grievances, disciplinary matters and other employee relations cases.

Why are more DSARs landing with HR?

There is rarely one reason. In the cases our consultants are supporting, a common thread is a breakdown in trust between an employee and their employer. An employee may feel that a process has not been followed properly, that their concerns have not been taken seriously, or that they do not have the full story behind a decision.

A DSAR can then become another way of seeking information about what has happened.

We are also seeing employees become more confident about making requests, following up on them and questioning how quickly their employer is responding.

Another development is the use of AI to help employees draft requests. This can result in lengthy or very broad DSARs, sometimes asking for information spanning several years without being clear about the particular information being sought.

For the HR team receiving that request, working out exactly what needs to be searched for can be one of the first difficulties.

Where do HR teams tend to struggle?

The challenge is often less about knowing that a DSAR needs a response and more about managing what happens next.

How wide should the search be? What information needs to be included? What needs to be redacted? What about duplicated information, information the employee already holds, third-party data or legally privileged material?

There are also deadlines to manage, often while the HR team is dealing with the employee relations issue that led to the request in the first place.

For an internal team with limited experience of handling DSARs, reviewing what could be a significant volume of material can quickly become a substantial piece of work.

And there can be wider risks hidden within that material.

Emails and internal correspondence may contain comments or information that create problems for the employer if there is an ongoing grievance, dispute or potential claim. Identifying those issues before the response is provided can therefore be important.

What should employers take from the increase?

A DSAR should not automatically be treated as evidence that something has gone wrong. But where a request arrives during an employee relations issue, it is worth considering the wider context.

If the employee feels unheard, does not understand how a decision was reached or has lost confidence in the process, responding to the DSAR is only one part of the situation.

Good record keeping matters too. HR teams need to consider how employee information is recorded and retained throughout the employment relationship, rather than only thinking about it once a request arrives.

The more complex the employee relations issue, the more important that becomes.

Getting support when a DSAR lands

Employers do not necessarily have to manage the process alone. Our HR consultants can provide support on individual DSARs, including helping employers establish the parameters of a request and managing correspondence with the employee.

Our team can also review the documents identified through the search process, including:

  • identifying duplicate or irrelevant material
  • redacting information where appropriate
  • identifying legally privileged material
  • identifying information the employee already holds
  • flagging material that may present a wider risk to the organisation

A dedicated consultant can manage the process with the employer, hold regular update meetings and maintain a tracker showing how documents have been reviewed and handled.

This support is available on a pay-as-you-go basis, so employers can bring in additional HR expertise for a specific DSAR without needing an ongoing retained service.

For HR teams already managing a difficult employee situation, that can provide extra capacity and experienced support at the point it is needed most. 

Dealing with a DSAR and need additional support?

Speak to our HR Consultancy team about the request you're dealing with and how we can help.

Speak to our team