Q&As

Can a limited company make a subject access request? Can a director of a limited company ask for recordings of calls with us? If yes, what personal data must we provide?

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Produced in partnership with Peter Steel of Bevan Brittan
Published on: 21 January 2019
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This Q&A draws on the information commissioner’s Office’s (ICO’s) guidance on business-to-business marketing, which may or may not be relevant dependent on the nature of the calls.

A limited company cannot make a subject access request, but a director can. The recording of a call may contain a variety of personal data. When recording calls, you must be sure that it is lawful for you to record them under the UK General data protection Regulation, Assimilated Regulation (EU) 2016/679 (GDPR) and Data Protection Act 2018 (DPA 2018).

Personal data is defined in Article 4 of the GDPR as:

‘…any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Personal data definition
What does Personal data mean?

Personal data means data relating to a living individual who can be identified from such data, either alone or with other information in the data controller’s possession. It includes opinions about, and intentions in relation to the data subject.

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