Employee DSARs: What You Need to Know

Employees Have Data Rights Too

As part of your privacy compliance obligations, it is important to recognize that data subject access requests do not only come from customers. Employees -- current, former, and prospective -- have the same legal right to request access to the personal data you hold about them under regulations like the GDPR and CCPA.

From a governance standpoint, employee DSARs tend to be more complex than consumer requests for several reasons:

• Breadth of data -- Employee records span HR files, payroll, email, performance reviews, internal messaging, CCTV, and access logs. The data footprint is typically much larger than a customer's.
• Sensitive timing -- These requests often coincide with disciplinary proceedings, workplace disputes, or terminations, which raises the stakes significantly.
• Exemption complexities -- Questions around legal privilege, third-party redaction, and investigation confidentiality arise more frequently with employment data.
• Manager awareness -- Anything a manager writes about an employee in emails, reviews, or notes is disclosable personal data. Many organizations are unprepared for this.

Getting your internal processes right before a request arrives is the most effective way to manage the risk. That means mapping where employee data lives, training managers on what constitutes disclosable information, and having a clear response workflow in place.

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Build your DSAR readiness now. Download the DSAR Compliance Guide for a structured framework covering intake, verification, and response -- including employee-specific scenarios.