Contracts: terms and dates
Check each contract for its renewal and notice terms, because a missed notice date can mean another full term (for example in an auto-renewing contract), depending on the contract. A sheet with the page and quoted text for each date lets anyone check it in seconds, and dates that depend on how notice counts belong to your lawyer. The limits and rights that are not dates, such as liability and termination, go in a second sheet in the same way.
Subject access requests: know the clock
The ICO guide says you must respond within one month of receiving the request, and the month can start late or pause for a clarification. You can add up to two more months for a complex request, but only if you tell the person within the first month and say why.
A reasonable search and a documented decision
The same guide says the search must be reasonable and proportionate. If you rely on an exemption you must be able to justify it, and the guide advises documenting your reasons. Those decisions belong to your named handler.
Which paid job fits
The contract dates job lists renewal dates and notice periods with the page and exact clause, and a monthly service keeps them current. The terms-sheet job lists the other key terms, such as liability and termination, with page and quote. The runbook job sets up the steps, tracker and search plan and tests them on a dummy request, with the legal calls left to your handler.
Sources and limits
- ICO: a guide to subject access Checked 2026-10-12.
- You must respond without undue delay and at the latest within one month of receiving the request; the month runs from receipt, or from when requested ID, proof of authority or a fee arrives.
- If you ask the requester to clarify, the clock pauses on the day you ask and restarts the day after their answer arrives.
- You can add up to two more months where necessary because the request is complex or the person has sent several, but you must tell them and explain why within the first month.
- You must make a reasonable and proportionate search, and you do not have to carry out searches whose effort is out of balance with the importance of the information.
- If you rely on an exemption you must be able to justify it, and the guide advises documenting your reasons.
- If you refuse a request you must say why and tell the person that they can complain to you, to the ICO and seek to enforce the right through the courts.