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Data Subject Request Procedure Template (GDPR DSAR, CCPA)

DSAR procedure: rights by regime, intake, identity checks, search plan, GDPR and CCPA deadlines, exemptions, per-right checklists, letters, log, metrics

ISO y cumplimientoCompletaGDPR Arts 12-23; EDPB Guidelines 01/2022 v2.1; CCPA Civ. Code 1798.100 ff.; CCPA Regulations (eff. 2026-01-01)datasubjectrequestprocedure

Cómo usar: Use it to set up or audit how your organization answers access, erasure and other rights requests under the GDPR, UK GDPR and CCPA. Fill the rights table, intake channels and deadline rules first, then the letters. The main pitfall is starting the clock late or demanding ID documents from requesters you can already identify.

Vista previa

Data Subject Request Procedure: [Organization name]

A procedure for receiving, verifying, answering and recording requests from individuals who exercise their data protection rights: access, rectification, erasure, restriction, portability, objection and rights related to automated decisions. Based on the EU General Data Protection Regulation (Regulation (EU) 2016/679, GDPR) Articles 12 to 22 and EDPB Guidelines 01/2022 on the right of access (version 2.0 adopted 28 March 2023, current version 2.1 with minor corrections), with a variant for consumer requests under the California Consumer Privacy Act (Civil Code sections 1798.100 to 1798.199.100, CCPA) and the CCPA Regulations (effective 1 January 2026). Dates and rules were checked on 2026-10-30; check the current official texts before use. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice; check the current official text and a qualified professional.

Document control

FieldValue
Document ID[PRIV-PROC-DSR-001]
Version[0.1]
Status[Draft / In review / Approved / Superseded]
Owner[@privacy-lead or DPO]
Approvers/reviewers[@dpo], [@legal-counsel], [@ciso], [@customer-service-head]
Controller or business[Legal name, establishment, registration number]
Regimes covered[EU GDPR / UK GDPR / CCPA / Other]
Lead supervisory authority[Authority name, if one-stop-shop applies]
Last updatedYYYY-MM-DD
Next reviewYYYY-MM-DD
Classification[Internal]

Approvals

RoleNameDecisionDate
Data protection officer[@name][Approve / Approve with conditions / Reject]YYYY-MM-DD
Legal counsel[@name][Decision]YYYY-MM-DD
Head of customer service[@name][Decision]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]First draft
1.0YYYY-MM-DD[@name]Example: Approved, CCPA variant added
1.1YYYY-MM-DD[@name]Example: Updated for CCPA Regulations effective 1 January 2026

Contents

  1. Purpose, scope and roles
  2. Rights and regimes covered
  3. Intake channels and recognising a request
  4. Logging and acknowledgement
  5. Identity verification and authorised agents
  6. Clarifying scope and searching
  7. Deadlines and extensions
  8. Exemptions, restrictions and refusals
  9. Fulfilling each right
  10. Response letters
  11. Request log, records and metrics
  12. Training, quality checks and review
  13. Glossary and references

1. Purpose, scope and roles

This procedure makes sure that every request from an individual about their personal data is recognised, verified, answered within the legal time limit, and recorded, and that refusals are justified and reviewed.

It applies to all staff, contractors and processors who may receive a request through any channel, and to all personal data held by [Organization] as controller (GDPR) or business (CCPA).

RoleResponsibility
Procedure owner[@privacy-lead]: maintains the procedure, reports metrics, approves extensions
Data protection officerAdvises on complex cases, approves refusals and partial refusals
Request handlerLogs, verifies, coordinates the search, drafts the response
System ownersSearch their systems and return results within [5] working days
Legal counselReviews requests linked to disputes, litigation or regulators
Processors and service providersForward requests within [2] working days and assist under the contract (GDPR Art. 28(3)(e))
Any employeeForwards a request to [privacy@example.com] on the day of receipt

2. Rights and regimes covered

2.1 EU GDPR and UK GDPR

RightGDPR articleApplies whenNotes
Information on how to exercise rightsArt. 12AlwaysConcise, clear, free of charge, written or electronic
AccessArt. 15AlwaysConfirmation, copy of the data and the processing information in Art. 15(1)(a) to (h) and 15(2)
RectificationArt. 16Data is inaccurate or incompleteIncludes completing data with a supplementary statement
ErasureArt. 17One of the grounds in Art. 17(1) appliesExceptions in Art. 17(3)
RestrictionArt. 18Accuracy contested, unlawful processing, data needed for legal claims, objection pendingData stored but not otherwise used
Notification to recipientsArt. 19After rectification, erasure or restrictionTell recipients unless impossible or disproportionate; tell the person who they are on request
PortabilityArt. 20Consent or contract basis and automated processingStructured, commonly used, machine-readable format
ObjectionArt. 21Legitimate interests or public task basis; always for direct marketingDirect marketing objection is absolute
Automated decisionsArt. 22Decision based solely on automated processing with legal or similarly significant effectsHuman intervention, express a view, contest the decision
Restrictions by lawArt. 23Union or Member State law restricts a rightRecord the specific law relied on

The UK GDPR keeps the same article numbering. The Data (Use and Access) Act 2025 amends the UK rules on subject access, including a statutory basis for limiting searches to what is reasonable and proportionate and for pausing the time limit while the controller waits for clarification. Check on legislation.gov.uk and in the ICO guidance which of these provisions are in force on the date you handle a request.

2.2 CCPA variant (California)

Consumer rightCivil Code sectionVerification requiredNotes
Know (categories and specific pieces)1798.100, 1798.110, 1798.115YesCovers the 12 months before the request, and earlier data back to 1 January 2022 if the consumer asks and the business holds it
Delete1798.105YesExceptions in 1798.105(d); tell service providers and contractors
Correct1798.106YesCommercially reasonable efforts
Opt out of sale or sharing1798.120NoAct within 15 business days (Regulations section 7026)
Limit use of sensitive personal information1798.121NoAct within 15 business days (Regulations section 7027)
No retaliation1798.125Not applicableDo not deny goods or change prices because a right was exercised
Access and appeal rights for automated decisionmaking technology (ADMT) used for significant decisionsCCPA Regulations Article 11 (section 7200 and following)Yes for accessAdded by the regulations effective 1 January 2026; a business already using ADMT for significant decisions must comply by 1 January 2027 (section 7200(b))

Other US state privacy laws give similar rights with different deadlines and appeal processes. List each one that applies to you in an extra column of section 7.

3. Intake channels and recognising a request

3.1 Channels

ChannelMonitored byHoursForwarding rule
Web form [URL]Privacy teamContinuousAutomatic ticket
Email [privacy@example.com]Privacy teamWorking daysTicket created on receipt
Toll-free telephone [number] (CCPA, where required by Regulations section 7020)Customer service[Hours]Call note forwarded the same day
Post [address]MailroomWorking daysScanned and forwarded the same day
In-app or account settingsProduct teamContinuousAutomatic ticket
Any other contact (social media, store, sales)Any employeeNot applicableForward on the day of receipt

Under the CCPA Regulations, a business that operates only online and has a direct relationship with the consumer may offer an email address alone for requests to delete, correct and know; other businesses offer two or more methods, one of them a toll-free number, and a website method if they have a website. If a consumer uses another method, either treat the request as received or explain how to submit it.

3.2 Recognising a request

A message is a data protection request when the person asks, in any words, to see, copy, correct, delete, move or stop using personal data about them, or objects to how it is used. The person does not need to name the law, use the word "request" or give reasons. When in doubt, treat it as a request and log it.

Requests that look like data protection requests but follow other rules, such as a request for documents in litigation or a freedom of information request to a public body, are logged and routed to [legal counsel] for a decision on which rules apply.

4. Logging and acknowledgement

Log every request within [1] working day of receipt with the fields in section 11. Then send an acknowledgement (letter L1 in section 10) that states the request received, what happens next, whether identity information is needed, and the date by which a response is due.

RegimeAcknowledgement rule
GDPRNot a legal requirement; EDPB Guidelines 01/2022 recommend confirming receipt in writing and stating the period that applies
CCPAConfirm receipt and explain how the request will be processed within 10 business days of receipt for requests to delete, correct and know (Regulations section 7021(a))

5. Identity verification and authorised agents

5.1 Verification levels

LevelUse whenMethodExample
V0Request comes from an authenticated account sessionRely on the sessionCustomer signed in and used the privacy dashboard
V1Low-risk data, request from a known contact pointMatch two data points already heldEmail address on file plus last order number
V2Specific pieces of data, sensitive data, or harmful if disclosed to the wrong personMatch three data points already held, plus a signed declaration for CCPA specific piecesAddress, phone number, recent payment amount
V3Account takeover suspected, or no data held to matchEscalate to the DPO for a proportionate methodOut-of-band call to the number on file

GDPR rule: ask for additional information only where you have reasonable doubts about the requester's identity (Art. 12(6)), and only what is necessary. Where you cannot identify the person at all, explain that (Art. 11(2) and 12(2)). According to the EDPB guidelines, the time limit may be suspended while you wait for identity information you asked for without undue delay.

CCPA rule: match identifying information to data already held before asking for more; a reasonable degree of certainty for categories, a reasonably high degree of certainty for specific pieces, which may include three data points and a signed declaration under penalty of perjury (Regulations sections 7060 to 7062). The 45-day period runs from receipt whatever time verification takes. Do not require verification for opt-out of sale or sharing and for requests to limit.

5.2 Authorised agents and representatives

CaseWhat to check
Parent or guardian for a childParental responsibility and the child's own interests, considering the child's maturity
Lawyer or representative under the GDPRWritten authority from the data subject, and identity of the data subject where reasonable doubt exists
CCPA authorised agentSigned permission from the consumer; you may also ask the consumer to verify their own identity or confirm the permission directly (Regulations section 7063)
Third-party request platformsTreat as an agent: confirm the mandate, never ignore the request

6. Clarifying scope and searching

6.1 Clarifying the request

Ask the requester to specify the information or processing their request relates to only when you process a large quantity of information about them (GDPR Recital 63), and do not use clarification to delay or narrow a request the person did not want narrowed. Without a reply, answer the request as made.

6.2 Search plan

System or sourceROPA referenceOwnerSearch keyIncludes processorsDone
CRM (Example)ROPA-04[@crm-owner]Customer ID, emailNo[Yes / No]
Order and payment database (Example)ROPA-02[@commerce-owner]Customer IDPayment processor[Yes / No]
Customer service tickets and call recordings (Example)ROPA-07[@cx-owner]Email, phoneHelpdesk SaaS[Yes / No]
Marketing platform (Example)ROPA-09[@marketing-owner]EmailEmail service provider[Yes / No]
Email and chat archives (Example)ROPA-12[@it-owner]Name, emailNo[Yes / No]
BackupsROPA-all[@it-owner]Only if data no longer exists in live systems and restoration is reasonableNo[Yes / No]
[Source][ROPA-NN][@owner][Key][Processor][Yes / No]

Freeze the data at the time of the search where possible: do not delete or change data because a request has arrived, and do not delay routine deletion only to avoid answering. Note the search date in the log.

7. Deadlines and extensions

7.1 Rules

RegimeFirst deadlineExtensionConditions for extension
GDPR Art. 12(3)Without undue delay and within one month of receiptUp to two further monthsNecessary because of complexity and number of requests; tell the person within the first month, with reasons
GDPR Art. 12(4) (no action taken)Without delay and within one month of receiptNoneExplain the reasons and the right to complain to a supervisory authority and to seek a judicial remedy
CCPA delete, correct, know (Regulations section 7021)Confirm within 10 business days; respond within 45 calendar days of receiptUp to 45 more calendar days, 90 in totalReasonably necessary; notice to the consumer within the first 45 days explaining the reason
CCPA opt out of sale or sharing, limitAs soon as feasibly possible, at most 15 business days from receiptNoneNot applicable

How to count a GDPR month, following EDPB Guidelines 01/2022 and Regulation (EEC, Euratom) No 1182/71: the period ends on the same date in the following month; where that date does not exist, on the last day of that month; where the last day falls on a weekend or public holiday, on the next working day.

7.2 Worked due dates

Request IDRegimeReceivedDay of weekDue dateExtended due dateReasoning
DSR-2026-0012 (Example)GDPR access2026-01-31Saturday2026-03-02Not extendedOne month gives 2026-02-28, a Saturday, so the next working day applies
DSR-2026-0027 (Example)GDPR erasure2026-02-10Tuesday2026-03-102026-05-11Extension notice sent 2026-03-04; three months gives 2026-05-10, a Sunday
DSR-2026-0035 (Example)CCPA know2026-03-02MondayConfirm by 2026-03-13, respond by 2026-04-152026-05-30 at mostCounting the day of receipt as day 1 for both periods, a conservative reading; 2026-05-30 is a Saturday, so plan to answer by Friday 2026-05-29
DSR-2026-0038 (Example)CCPA opt-out2026-03-04Wednesday2026-03-24Not applicable15 business days counting the day of receipt as day 1, no California state holiday in the period

Set internal milestones: search complete by day [10], draft response by day [20], DPO review by day [25] of the one-month period.

8. Exemptions, restrictions and refusals

8.1 Grounds to consider

GroundSourceEffectApproval needed
Manifestly unfounded or excessive requestGDPR Art. 12(5)Charge a reasonable fee based on administrative costs, or refuse; the burden of proof is on the controllerDPO
Rights and freedoms of othersGDPR Art. 15(4), Recital 63Redact third-party data or trade secrets; do not refuse the whole copyHandler, DPO for disputes
Erasure exceptionsGDPR Art. 17(3)(a) to (e)Keep data needed for freedom of expression, legal obligations or public tasks, public health, archiving or research, or legal claimsDPO
Restrictions in national lawGDPR Art. 23 and national implementing lawApply only the restriction the law provides, for its purposeLegal counsel
Unable to identify the personGDPR Art. 11(2), 12(2)Explain and invite more informationHandler
CCPA deletion exceptionsCivil Code 1798.105(d)Keep data needed for the listed purposes, such as completing a transaction, security, legal obligationsLegal counsel
CCPA data that must not be disclosedRegulations section 7024(d)Never disclose government ID numbers, financial account numbers, passwords, security questions or biometric data; say that you hold themHandler
CCPA unverifiable requestRegulations sections 7022 to 7024Deny the specific pieces, then treat a request to know as a request for categories where possibleHandler

8.2 Refusal record

Request IDGroundScope refusedEvidenceDecision byPerson told of complaint route
DSR-2026-0044 (Example)Art. 12(5) excessive: the same access request sent weekly for 6 weeks with no change in processingRepeat copies only; first copy providedTicket history[@dpo]Yes, letter L5
[DSR-ID][Ground][Scope][Evidence][@name][Yes / No]

9. Fulfilling each right

9.1 Access (GDPR Art. 15)

  • Confirm whether personal data about the person is processed.
  • Provide a copy of the personal data, in a commonly used electronic form if the request was electronic, unless the person asked otherwise (Art. 15(3)).
  • Provide the processing information: purposes; categories of data; recipients or categories of recipients; retention period or criteria; the rights to rectification, erasure, restriction and objection; the right to complain to a supervisory authority; the source where data was not collected from the person; and the existence of automated decision-making with meaningful information about the logic and consequences (Art. 15(1)(a) to (h)).
  • Describe safeguards for transfers to third countries (Art. 15(2)).
  • Redact third-party data where Art. 15(4) applies and record why.
  • Explain codes and abbreviations so the copy is intelligible.
  • Send through a secure channel; protect files with a password sent separately.

9.2 Rectification, erasure and restriction (Art. 16 to 19)

  • Check the ground or accuracy claim; for disputed accuracy, restrict processing while checking (Art. 18(1)(a)).
  • Correct, erase or restrict in every system in the search plan, including processors.
  • For erasure of data made public, take reasonable steps to inform other controllers processing it (Art. 17(2)).
  • Notify recipients under Art. 19 unless impossible or disproportionate; tell the person who they are if asked.
  • Keep a minimal suppression record (for example a hashed email) where needed to honour the request in future, and say so in the response.
  • Backups: record when the data will age out of backups and that it will not be restored into live use.

9.3 Portability (Art. 20)

  • Confirm the basis is consent or contract and processing is automated.
  • Export data the person provided, including observed data such as activity logs, in a structured, machine-readable format such as JSON or CSV.
  • Transmit directly to another controller where technically feasible and requested.

9.4 Objection and automated decisions (Art. 21 and 22)

  • Direct marketing objection: stop at once, across all channels.
  • Other objections: stop unless compelling legitimate grounds that override the person's interests exist, or the data is needed for legal claims; document the balancing (link the legitimate interests assessment).
  • Automated decisions: offer human review by a person with authority to change the outcome, let the person give their view, and record the result.

9.5 CCPA requests

  • Know: disclose categories or specific pieces for the period required, in a portable and readily usable format for specific pieces; never disclose the data listed in Regulations section 7024(d).
  • Delete: delete from live systems, deidentify or aggregate; tell service providers, contractors and, where relevant, third parties to whom data was sold or shared; record any exception relied on.
  • Correct: consider the totality of the information, document the decision, and tell the consumer whether the correction was made.
  • Opt-out and limit: act within 15 business days and honour opt-out preference signals as the regulations require.
  • Explain the right to complain and any appeal process you offer.

10. Response letters

LetterWhenMust contain
L1 AcknowledgementWithin [3] working days (CCPA: 10 business days)Request ID, received date, due date, verification step if any
L2 Identity information neededReasonable doubt about identityWhat is needed, why, how it will be used and deleted
L3 Extension noticeBefore the first deadlineReasons, new due date
L4 ResponseOn fulfilmentAction taken per right, the data or a link, the information required by section 9
L5 Refusal or partial refusalWhen any part is refusedReasons, the right to complain to a supervisory authority and to seek a judicial remedy (GDPR Art. 12(4)), or the CCPA complaint route

Example L3 extension notice:

Dear [Name],

We received your request to delete your personal data on 10 February 2026 (reference DSR-2026-0027). Your account is linked to orders, warranty records and marketplace accounts held in four separate systems, and two of our service providers hold copies. We need more time to complete the deletion safely, so we are extending the deadline as the GDPR allows (Article 12(3)). You will receive our answer by 11 May 2026 at the latest, and sooner if we can.

If you are not satisfied with how we handle your request, you can contact our data protection officer at [contact], complain to [supervisory authority] or seek a judicial remedy.

[Name], Privacy team, Quillmoor Homewares Ltd

11. Request log, records and metrics

11.1 Log fields

FieldContent
Request IDDSR-YYYY-NNNN
Received date and channelDate that starts the clock
RegimeGDPR, UK GDPR, CCPA, other
Rights requestedAccess, erasure and others
Verification level and date verifiedV0 to V3
Due date and extended due dateComputed under section 7
Systems searchedFrom the search plan
OutcomeFulfilled, partially fulfilled, refused, withdrawn
Exemptions appliedGround and approver
Response dateDate sent
Handler[@name]

Retain the log for [period]; the CCPA Regulations require records of requests and responses for at least 24 months (section 7101). Businesses that handle the personal information of 10,000,000 or more consumers in a calendar year also compile and disclose yearly request metrics (section 7102).

11.2 Metrics

MetricQ1 2026 (Example)Target
Requests received184 (access 92, erasure 51, rectification 14, objection or opt-out 19, portability 8)Not applicable
Closed within the legal deadline171 of 184 (92.9%)100%
Extended7 of 184 (3.8%)Under [5%]
Refused in whole or in part[n]Reviewed by DPO
Median days to close[n]Under [15]
Complaints to a supervisory authority[n]0

12. Training, quality checks and review

  • Train customer-facing staff at onboarding and yearly to recognise and forward requests.
  • The DPO samples [10%] of closed requests each quarter for completeness, timeliness, redaction quality and tone, and records findings.
  • Review the procedure yearly, after a complaint or regulator inquiry, after a significant system change, and when a law, regulation or EDPB or ICO guidance changes.
  • Report metrics and sample findings to the management review.

13. Glossary and references

13.1 Glossary

TermMeaning in this document
Data subjectThe identified or identifiable living person the data relates to (GDPR)
ConsumerA natural person who is a California resident (CCPA)
ControllerThe body that decides the purposes and means of processing (GDPR)
BusinessThe CCPA term for the entity that determines purposes and means and meets the CCPA thresholds
Processor, service provider, contractorBodies that process data on behalf of the controller or business
DSARData subject access request, often used for any rights request
Verifiable consumer requestA CCPA request the business can verify under the regulations

13.2 References

ReferenceVersion or dateUse
Regulation (EU) 2016/679 (GDPR), OJ L 119, 4.5.2016Applies from 25 May 2018; check the consolidated text and any pending amendmentsArticles 11, 12 to 23, 28
EDPB Guidelines 01/2022 on data subject rights, right of accessVersion 2.1 (version 2.0 adopted 28 March 2023, minor corrections 30 May 2024)Receipt, identity, time limits, format
Regulation (EEC, Euratom) No 1182/71 on periods, dates and time limits3 June 1971Counting months
California Civil Code sections 1798.100 to 1798.199.100 (CCPA as amended by the CPRA)Check the current text on leginfo.legislature.ca.govConsumer rights and timing
CCPA Regulations, California Code of Regulations Title 11, Division 6, Chapter 1Effective 1 January 2026Sections 7020 to 7027, 7060 to 7063, 7101, 7102
UK GDPR and Data Protection Act 2018, as amended by the Data (Use and Access) Act 2025Check commencement on legislation.gov.ukUK variant
ICO guidance on the right of accessUpdated 8 December 2025UK variant

Standard and licence note

Based on Regulation (EU) 2016/679 (GDPR) as published in the Official Journal of the European Union, EDPB Guidelines 01/2022 version 2.1, the California Consumer Privacy Act (Civil Code section 1798.100 and following) and the CCPA Regulations effective 1 January 2026. Articles, sections and time limits are cited and summarised in original wording; no legal text is reproduced beyond short references. Laws, regulations and guidance change: check the current official texts at https://eur-lex.europa.eu/eli/reg/2016/679/oj, https://www.edpb.europa.eu/our-work-tools/our-documents/guidelines/guidelines-012022-data-subject-rights-right-access_en, https://leginfo.legislature.ca.gov and https://cppa.ca.gov/regulations/ before use. This is a documentation format, not legal advice; check the current official text and a qualified professional. Template licence: MIT.

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