DSAR Identity Verification: The Basics

Verification: The Risk You Cannot Afford to Get Wrong

Identity verification sits at a critical juncture in the DSAR process. Verify too loosely, and you risk disclosing personal data to an unauthorized person — creating a data breach that you caused. Verify too aggressively, and you obstruct a legitimate right of access, which regulators treat as noncompliance.

The governing principle across GDPR, CCPA, and other privacy frameworks is proportionality: the level of verification you require should match the sensitivity of the data and the risk of disclosure to the wrong individual.

In practice, this means your verification approach should differ based on context:

• Known customers contacting you from a verified account — minimal additional verification may be sufficient
• Former employees or individuals you have limited records for — matching against two or three data points you already hold is standard
• Strangers or unrecognized requesters — more robust verification is justified, but you still cannot demand excessive documentation
• Requests via authorized agents — you can require confirmation from the data subject directly

The most common mistakes organizations make are demanding government-issued ID for every request regardless of context, and using verification as a delay tactic. Both draw regulatory scrutiny.

A defensible verification process is documented, proportionate, and applied consistently.

Get the Full Verification Framework

Our Identity Verification Guide walks you through building a proportionate, regulation-compliant verification process — with decision trees, sample correspondence, and jurisdiction-specific requirements.

Download the Identity Verification Guide