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DPA Subject Access Request

DPA Subject Access Request Template for Germany

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Key Requirements PROMPT example:

DPA Subject Access Request

"I need to draft a DPA Subject Access Request response for our German subsidiary's employee who has requested access to all their HR data, including performance reviews and monitoring data collected since January 2025, ensuring compliance with both GDPR and German labor law requirements."

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Document background
The DPA Subject Access Request response document is a mandatory compliance requirement under both the GDPR and German Federal Data Protection Act (BDSG). It must be provided when an individual (data subject) exercises their right to access their personal data under Article 15 GDPR. The document must be provided within one month of receipt of the request (with possible extension under specific circumstances) and should contain comprehensive information about all personal data processing activities, including the purposes of processing, categories of data, recipients, retention periods, and data subject rights. This response template is specifically designed to meet German legal requirements while ensuring full GDPR compliance, incorporating necessary elements to address both EU-wide and German-specific data protection obligations.
Suggested Sections

1. Identity Confirmation: Confirmation of the data subject's identity and verification of their right to access

2. Request Acknowledgment: Formal acknowledgment of the subject access request, including date received and reference number

3. Processing Confirmation: Confirmation whether personal data concerning the data subject is being processed

4. Data Categories: List of categories of personal data being processed

5. Processing Purposes: Detailed explanation of the purposes for which the data is being processed

6. Recipients Disclosure: Information about recipients or categories of recipients with whom data has been or will be shared

7. Retention Period: Information about the planned data retention period or criteria used to determine it

8. Data Subject Rights: Information about the right to rectification, erasure, restriction of processing, and right to object

9. Complaint Rights: Information about the right to lodge a complaint with a supervisory authority

10. Data Source: Information about the source of the data (if not collected directly from the data subject)

11. Automated Decision-Making: Information about any automated decision-making, including profiling, and related logic

Optional Sections

1. International Transfers: Required only if personal data is transferred to third countries or international organizations, including information about appropriate safeguards

2. Additional Data Subject Information: Any additional information specific to the data subject's circumstances or special categories of data

3. Processing Restrictions: Include when there are specific limitations or restrictions on the processing of the data subject's information

4. Third-Party Rights: Required when the response contains information about other individuals and explains handling of such third-party data

Suggested Schedules

1. Data Inventory: Detailed list of all personal data held about the data subject, organized by data category

2. Processing Activities Log: Chronological log of processing activities related to the data subject's personal data

3. Data Sharing Record: Detailed record of all instances where the data subject's data has been shared with third parties

4. Technical Glossary: Explanation of technical terms and processing methods used in the response

5. Supporting Documentation: Copies of relevant documents, such as privacy notices or consent forms, referenced in the response

Authors

Alex Denne

Head of Growth (Open Source Law) @ tiktok³ÉÈË°æ | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

alex.den.21@genieai.co
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Financial Services

Healthcare

Technology

Retail

Education

Insurance

Telecommunications

Professional Services

Manufacturing

Public Sector

Entertainment

Transportation

Energy

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Non-Profit Organizations

Relevant Teams

Legal

Compliance

Data Protection

Information Security

Risk Management

Privacy Operations

Information Management

Records Management

Data Governance

Regulatory Affairs

Relevant Roles

Data Protection Officer

Privacy Manager

Legal Counsel

Compliance Officer

Information Security Manager

Risk Manager

Privacy Analyst

Data Protection Specialist

Compliance Manager

Legal Operations Manager

Privacy Operations Director

Data Governance Manager

Records Manager

Information Management Officer

Chief Privacy Officer

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Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

Find the exact document you need

DPA Subject Access Request

A formal response document to a data subject access request under German law and GDPR, detailing personal data processing information and subject rights.

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