The new guidance is much clearer and more user friendly than previous guidance on the meaning of personal data. It includes many practical examples of what type of information might count as personal data and in what circumstances. For example, it discusses what type of information in the minutes of a meeting might count as personal data. However, its interpretation of the meaning of personal data is in places rather wide.
Individuals have the right to see the personal data you hold about them if they make what is known as a proper ‘subject access request’. If you are unable to agree with the individual what documents they would like to see, the new Guidance may be a useful tool to help you work out which records you are obliged to disclose.
We recommend that you also read Chapter 9 of the EEF guide, ‘Data Protection: A Practical Guide for Employers’ which provides advice on how to respond to requests from individuals to see the information you hold about them.
The Information Commissioner has not yet produced updated guidance on what type of paper records are covered by the Data Protection Act 1998.