Bar 30jan 2020 LF

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CHIEF EXECUTIVE

DAVID MULHOLLAND

Mr John Walsh
Email: bt126ar@hotmail.com

30th January 2020

Dear Mr. Walsh

Further to my previous correspondence confirming that I would carry out a review our
Subject Access Request procedures after your recent Subject Access Request to us and
our response.

After a full review of the documents and emails in which you can be identified through
Personal Data, I can advise you that they all fall into the one of the following three
distinct categories:

1. Correspondence between you and the PCC Secretary – (This documentation has
been provided to you in our SAR response)

2. Formal responses from various parties (other than the complainant) to PCC
requests for information as part of their investigation. As well as containing
information on the processes and decisions of the PCC, they also contain
references to other identifiable Data Subjects

3. Emails between the PCC Secretary and PCC Members and/or PCC Chair where
the you are referenced by name in the preamble for case identification purposes
only, but where the email body, and/or attached documents fall into Category 2
above.

The documents in categories 2 and 3 above:

• are integral to the independence, impartiality and confidentiality of the PCC to


investigate complaints

• contain Personal Data identifying multiple other Data Subjects who have been
91 CHICHESTER STREET
given assurances of confidentiality and privacy by the PCC and have not given
BELFAST, BT1 3JQ explicit consent to have their Personal Data shared with others.
NORTHERN IRELAND

Telephone
+44(0) 28 9056 2050

Email
Clare.Rice@barofni.org

Website:
www.barofni.com
CHIEF EXECUTIVE
DAVID MULHOLLAND

I am therefore content that our recent response to your Subject Access Response rightly
withheld these documents under Schedule 2 Part 2 Section 7 and Part 3 Section 16 of
the Data Protection Act 2018.

Yours Sincerely,

David Mulholland
Chief Executive

91 CHICHESTER STREET
BELFAST, BT1 3JQ
NORTHERN IRELAND

Telephone
+44(0) 28 9056 2050

Email
Clare.Rice@barofni.org

Website:
www.barofni.com

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