Previous S.184 considerations:
21/12/2018 – ICO – Case Reference IC-02622-G8Q7 from the ICO:
- ‘I have carefully reviewed the points you make and have come to the view that my previous advice was mistaken and that you are correct.
- It does indeed seem that the relevant records only relate to health or criminal conviction data, or to information obtained through such a request in relation to statutory functions.
Please accept my apologies and I am now of the view that the type of data you wish to advise your customer to obtain would not constitute a ‘relevant record’ under Section 184 of the Data Protection Act 2018.[1]
And, regarding Thames Valley Police (TVP):
23/03/2023 – ICO – Case reference: IC-220316-G1X1 from the ICO :
- Thank you for your email of 13 March 2023. I have considered your response, and without knowing exactly what you are asking for from the Police, it is difficult to say definitively.
- However, if you aren’t requiring another person to make and provide the results of a SAR for a ‘relevant record’ (which is: is a health record, a record that relates to a conviction or caution, or information relating to a statutory function), then it would not be an enforced SAR under the legislation.
More recently, 16/07/2025 ICO & Essex police – ‘no offence, disclose the information’
[1] https://cmaclaims.co.uk/enforced-subject-access-requests-sar/
