Posted: 28th November 2023

Clients are increasingly reaching out to us to discuss how they can manage fluctuating Data Subject Access Request (DSAR) volumes. Increased DSAR volumes are typically driven by external factors: court and Financial Ombudsman Service decisions, CMCs and broader promotion through the press and media. A number of recent industry issues have the potential to impact DSAR volumes, including:

  1. Potter vs Canada Square: A significant challenge faced by organisations is posed by the aftermath of the Potter vs Canada Square case. In the wake of this decision, businesses must carefully reassess how they have applied time bars to Payment Protection Insurance (PPI) complaints. Furthermore, they need to scrutinise whether there has been any deliberate concealment of commission rates and crucially understand what population of cases are potentially impacted so they can forecast potential volumes.
  2. Unveiling irresponsible lending: Another pressing issue for businesses is the surge in DSARs related to irresponsible lending. Clients are witnessing a heightened demand for the underlying customer information that supports lending decisions. This necessitates a robust mechanism to manage increased requests for sensitive product / customer data, while ensuring compliance with data protection regulations.
  3. Commission disclosure in financial services: Organisations are also facing a growing number of DSARs related to commission disclosure. Clients are increasingly seeking information about the level of commission paid on various financial services products. This shift places an added burden on organisations to not only identify and compile this data but also to do so in a manner that aligns with regulatory requirements.

As businesses navigate this surge, they face specific challenges that necessitate strategic and nuanced solutions. Our extensive experience within the PPI review and remediation space is unmatched, having helped to deliver some of the largest programmes in the industry – we are well placed to provide support with DSAR activity and any follow up work which may materialise.

Our commitment to compliance, especially in highly regulated industries, helps organisations mitigate legal risks and build trust with customers. We have managed DSARs across a variety of sectors, and have a large, readily deployable team of resource to ensure that you can manage increased demand effectively without compromising quality and compliance. 

On one client engagement alone, we implemented the following to deliver efficient, flexible and scalable support:

  1. Automated document requests and AI efficiency: We utilise robotics for automated document requests, simultaneously creating designated folders with a consistent naming convention. This not only streamlines the process but also enhances efficiency.
  2. Quality Control and Competency Framework for improved outcomes: Creating an enhanced Quality Control / Competency Framework improved customer outcomes, efficiency, and case handler competence further. This framework drove continuous improvement through root cause analysis and ongoing process enhancements alongside our other initiatives.
  3. Process maps and case document checklists: We designed and created comprehensive process maps and guides accompanied by case document checklists. These resources contributed to a comprehensive approach to case completion, ensuring thoroughness in every aspect of our service.

In summary, our extensive experience, commitment to compliance, and expertise in addressing specific DSAR challenges position us as a valuable partner for businesses seeking effective solutions in this dynamic landscape. By leveraging our resources and insights, organisations can not only meet the demands of the present but also build a foundation for resilient and compliant data management in the future.


Contact Emma Mitchell, Director of Advisory Services

Emma Mitchell


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