Right of rectification policy and procedure

Determining whether personal data is inaccurate can be more complex if the data refers to a mistake that has subsequently been resolved. It may be possible to argue that the record of the mistake is, in itself, accurate and should be kept. In such circumstances the fact that a mistake was made and the correct information should also be included in the individuals data.

It is also complex if the data in question records an opinion. Opinions are, by their very nature, subjective, and it can be difficult to conclude that the record of an opinion is inaccurate. As long as the records clearly shows that the information is an opinion and, where appropriate, whose opinion it is, it may be difficult to say that it is inaccurate and needs to be rectified.

Under the UK-GDPR, Article 18, an individual has the right to request the restriction of the processing of their personal data where they contest its accuracy and we are checking it. As a matter of good practice, we should restrict the processing of the personal data in question whilst we are verifying its accuracy, whether or not the individual has exercised their right.