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Research noteSH-2026-0155

Subject access requests used as reconnaissance

A legal obligation to disclose, exercised by someone impersonating the subject.

SeverityModerate

6 minB2B Compliance & DLP

Statutory deadlines create pressure to respond, and identity verification is the step most often compressed. A well-prepared request can extract a detailed profile of a real person from an organisation acting in good faith.

Verification proportionate to the sensitivity of the data is permitted and rarely applied consistently.

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