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View full libraryThis Subject Access Request (SAR) Refusal Letter provides a formal response where an organisation has decided that it cannot comply with all or part of a subject access request because a specific legal exemption or the manifestly unfounded or excessive provisions apply. It records the reason for refusal and explains the individual's rights to challenge the decision.
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[Sender name]
[Sender address]
[date]
[Recipient name]
[Recipient address]
Dear [Recipient first name],
Subject Access Request
Thank you for your Subject Access Request dated [Date], in which you requested access to your personal information held by [Company Name].
We have carefully considered your request and the information covered by it.
Following our assessment, we are unable to comply with [all / part] of your request in relation to the information described below.
Information to which the refusal applies
The information affected by this decision is:
[Describe the information or category of information being withheld without disclosing information that would undermine the exemption or restriction being relied upon.]
[Where the refusal is partial: The remainder of the information covered by your request will be provided separately / has been provided with this response.]
Reason for refusal
We are relying on [insert relevant exemption / provision] because [set out the specific reason why the exemption applies in this case].
[Where relying on legal professional privilege: The
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This letter provides a structured response where an organisation decides that it cannot comply with all or part of a subject access request. It is designed for situations where a specific exemption applies or where the request is manifestly unfounded or excessive and the organisation has documented evidence supporting that conclusion.
The letter confirms that the organisation has considered the request and clearly identifies whether the refusal applies to the whole request or only particular information. This helps distinguish a genuine refusal from a delay or incomplete response.
The organisation should identify the applicable exemption or other lawful basis for withholding the information. The wording should be tailored to the circumstances rather than relying on a generic statement that the request cannot be fulfilled.
Where information is withheld, the organisation should explain its reasoning to the extent that doing so does not itself undermine the purpose of the exemption. For manifestly unfounded or excessive requests, the organisation should have clear evidence supporting the decision.
A refusal does not necessarily need to apply to the entire SAR. Where some personal information can properly be provided, the organisation should consider whether the request can be complied with in part while withholding only information covered by an applicable exemption.
The response should tell the individual how they can complain to the organisation, complain to the Information Commissioner's Office and, where applicable, seek to enforce their rights through the courts.
Related HR resources and workflow
Explore the HR resources that may be relevant before and / or after using the Subject Access Request (SAR) refusal letter, helping you understand the wider process, maintain appropriate documentation and follow a consistent approach.
Use these best practice actions, recommended timescales and process stages to understand when and how the Subject Access Request (SAR) refusal letter should be used, helping ensure each step is handled consistently and appropriately documented.
Understand the common mistakes to avoid when using this HR template, helping you reduce risk, prevent unnecessary costs and ensure the process is handled correctly.
Yes, but only where a relevant exemption or restriction applies. A complete refusal is relatively unusual. The employer should first consider whether some or all of the requested personal information can be provided.
Not automatically. A large request is not necessarily excessive. The employer should consider whether the request is clearly or obviously unreasonable in the circumstances and should consider reasonable and proportionate searches before relying on the manifestly excessive provision.
Not simply for that reason. The ICO specifically indicates that the fact a requester may intend to use information in litigation does not, by itself, justify refusing a SAR. The employer must consider whether a specific exemption or other lawful basis applies.
Generally, the organisation should explain the reasons for refusing all or part of a request and identify the relevant exemption where appropriate. However, there are circumstances where providing detailed reasons could undermine the purpose of the exemption, so the explanation should be tailored to the case.
The individual can complain to the organisation and can also complain to the Information Commissioner's Office. They may also have a right to seek a judicial remedy. The refusal letter should explain these rights.
HRDocBox templates are designed around practical UK HR processes and current data protection requirements. This template provides a structured framework for documenting a sensitive SAR refusal while allowing the organisation to tailor the legal basis and reasoning to the particular circumstances.
How this content is developed and reviewed
The Subject Access Request (SAR) refusal letter template is developed using a practical HR methodology that considers current UK employment legislation, ACAS guidance, CIPD good practice and the real-world HR process it supports. Templates and supporting information are regularly reviewed and updated, with additional reviews triggered by significant changes to legislation, guidance or established HR practice, helping ensure each document remains practical, relevant and suitable for UK employers.
Darryl Horn, Chartered HR Director
Darryl is a Chartered HR professional with over 25 years' experience in senior HR and employee relations roles.
He has extensive practical experience of managing data access and privacy HR processes and founded hrdocbox to provide businesses with practical, professionally developed HR resources grounded in UK employment law and best practice.
HRDocBox has been creating practical UK HR documents since 2009.
"Darryl provides support and advice with excellent judgement, and has a strong understanding of people, policies and UK employment legislation."
"He is someone I trust; consistent, dependable, and committed to doing things properly."
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