On 7 July, the Home Office in the UK issued Home Office Circular 4/2021 which set out the position of the UK Government regarding the use of SAR in private civil litigation. Its basic position is that, as far as possible, reporters should avoid referring to SAR in the documentation of their internal decision-making processes. It concedes that in disputes or litigation obligations can arise under the Civil Procedure Rules or under an order of the court where it appears the SAR will become disclosable. The guidance provides the procedure to follow should this happen, involving contact with the NCA. It also deals with situations involving subject access requests under data protection law.
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