Data and privacy · Irish in-house counsel, DPO, HR lead
Answer a subject access request under Irish law
An employee in Dublin who is midway through a grievance has made a broad subject access request covering four years of email. The run scopes the request, applies the exemptions and produces the response letter.
- First draft
- A scoped response plan comes back from one run, early in the one-month period.
The problem
Step 01 of 05
Open the matter in Ireland
Jurisdiction is set to Ireland, and the request, the grievance file and the employer's retention schedule are uploaded with the one-month deadline recorded.
Project Halcyon: SPA warranties and disclosure
Buy-side warranty review, disclosure analysis and cited due-diligence grid.
- Client
- Halcyon Bidco Ltd
- Reference
- WC-2026-0412
- Practice area
- Corporate / M&A
- Jurisdiction
- England and Wales
- Responsible partner
- E. Vance
No conflict check on file.Chat, on this matter
Compare warranties with the disclosure letter.
Three high-priority exceptions require action: the unregistered charge, the change-of-control right and the tribunal claim.
Send a message… (@ to mention tools)BalancedPrepare for- 25 Aug
Disclosure exceptions matrix
Chat
- 21 Aug
Disclosure exceptions matrix
Run · completed · 560 credits
- 18 Aug
Project Halcyon: Disclosure Letter
Document · indexed
- 16 Aug
Project Halcyon: Share Purchase Agreement
Document · indexed
- 4 Aug
Matter opened
Opened
Step 02 of 05
Scope the request
Prepare for: Work-Stream Memo. The instruction asks what the request actually covers, whether any part can properly be narrowed by clarification, and what the extension position is.
Agent
Jurisdiction
Prepare for
Deliver as
Instruction
What should the agent look for?Documents
Drop a contract, or pick one from the matter
Also on the matter
- Offer_letter_v3.pdf2 pages
- Staff_handbook_2025.docx61 pages
- Board_minute_14_Aug.pdf3 pages
Platform model · zero data retention · audit register onStep 03 of 05
Apply the exemptions by category
Legal advice, third party data, management forecasting and negotiation material are each addressed against the categories of document identified rather than in the abstract.
6 items need your confirmation14 authorities · Where we lookedSenior Associate Employment Contract: English Law Review
Summary
- 1.
Clause 9(c), non-competeHigh
The 12-month prohibition on working for any law firm anywhere in the UK, Ireland or EU, in any capacity, is almost certainly wider than reasonably necessary and therefore unlikely to be enforceable.
Tillman v Egon Zehnder Ltd [2019] UKSC 32 - 2.
Clause 11, data and monitoringHigh
Blanket contractual consent is not an adequate basis for general employment processing, special-category data or unrestricted monitoring.
UK GDPR, Arts 6 and 9 - 3.
Clause 4, holiday carry-overHigh
The unconditional five-day cap conflicts with mandatory carry-over rights where sickness, statutory leave or employer failure prevents leave being taken.
Working Time Regulations 1998, regs 13 to 13A
- 1.
Step 04 of 05
Draft the response
The letter sets out what is being provided, what is withheld and the basis for withholding it, in language the employee can follow.
6 items need your confirmation14 authorities · Where we lookedSenior Associate Employment Contract: English Law Review
Summary
- 1.
Clause 9(c), non-competeHigh
The 12-month prohibition on working for any law firm anywhere in the UK, Ireland or EU, in any capacity, is almost certainly wider than reasonably necessary and therefore unlikely to be enforceable.
Tillman v Egon Zehnder Ltd [2019] UKSC 32 - 2.
Clause 11, data and monitoringHigh
Blanket contractual consent is not an adequate basis for general employment processing, special-category data or unrestricted monitoring.
UK GDPR, Arts 6 and 9 - 3.
Clause 4, holiday carry-overHigh
The unconditional five-day cap conflicts with mandatory carry-over rights where sickness, statutory leave or employer failure prevents leave being taken.
Working Time Regulations 1998, regs 13 to 13A
- 1.
Step 05 of 05
Keep the record
The run and the reasoning are written to the audit register, so the employer can show its decision trail if the request is escalated.
5 of 8 entries · digest sha-256Time Who Type Entry Matter 09:36 j.okafor Document Disclosure_letter_v4.docx uploaded · 18 pages HAL-2026-0031 09:30 e.vance Conflict check Conflict check on open · no matches across 38 matters RC-2026-0009 09:12 admin Member p.hartley added · role: Associate · 4 matters Workspace 08:55 r.chen Run Due Diligence Agent · review grid · 12 documents HAL-2026-0031 08:40 r.chen Verification Verify all · 6 authorities · 6 verified HAL-2026-0031 Exports carry a content digest so a reviewer can confirm nothing was edited after the fact.
What comes back
A document, not a transcript.
- A scope analysis covering what the request reaches and where clarification can properly be sought.
- Exemptions applied category by category, with the reasoning recorded for each.
- A drafted response letter that explains withholding without reciting statutory language at the employee.
- A decision trail in the audit register that can be produced if the request is escalated.
Authorities it checks
- Regulation (EU) 2016/679, art 12
- Regulation (EU) 2016/679, art 15
- Data Protection Act 2018 (Ireland)
What it does not do
- It does not search the mail system or collect the documents; the search is the employer's own exercise.
- It does not redact documents. It sets out the basis for redaction and a person applies it.
- It does not send the response letter or engage with the Data Protection Commission.