How to Handle Subject Access Requests (SARs) on UK E-Commerce Platforms

With data protection regulations becoming more stringent, handling SARs on UK e-commerce platforms has become a vital part of business operations. A Subject Access Request (SAR) allows individuals to request access to their personal data held by an organisation. Under the UK General Data Protection Regulation (UK GDPR), e-commerce platforms must respond promptly and transparently to such requests. Failure to do so can result in reputational damage and regulatory penalties.

For online retailers and service providers, understanding how to process SARs on UK e-commerce platforms is essential not only for legal compliance but also for building consumer trust. In this article, we explore what SARs entail, how to handle them, and how businesses can prepare for efficient responses.

What Is a Subject Access Request?

A Legal Right Under UK GDPR

A Subject Access Request gives individuals the right to access personal data that an organisation holds about them. This includes customer profiles, purchase history, correspondence, and even tracking data collected via cookies. SARs on UK e-commerce platforms are becoming more common as consumers grow increasingly aware of their digital rights.

While SARs have existed for years under the Data Protection Act, the UK GDPR has expanded and clarified these rights, emphasising transparency and accountability. Importantly, SARs are not just formal legal tools—they are expressions of consumer interest and concern.

What Does a SAR Typically Include?

When a customer submits a SAR, they may request details such as:

• Confirmation that their data is being processed
• Access to copies of the data held
• The purposes of processing
• Categories of personal data collected
• Data retention periods
• Information on third parties with whom the data is shared

Handling SARs on UK e-commerce platforms requires systems capable of identifying, extracting, and delivering this information securely and efficiently.

Legal Obligations for E-Commerce Businesses

Timeframes and Responses

Under the UK GDPR, businesses are required to respond to SARs within one month of receipt. This period can be extended by a further two months for complex requests, but the data subject must be informed within the initial month. This timeframe places pressure on e-commerce businesses, which often manage high volumes of customer data across multiple systems.

Therefore, having a robust process for responding to SARs on UK e-commerce platforms is essential to meet deadlines without compromising accuracy or security.

Cost and Refusal

In most cases, responding to a SAR is free of charge. However, if the request is manifestly unfounded or excessive, businesses may charge a reasonable fee or refuse to act. Even then, the burden of proof lies with the business, so caution and documentation are vital.

Companies must also verify the identity of the requester before releasing any data. Failing to do so could result in a data breach—a serious violation in itself.

Practical Steps to Handle SARs on UK E-Commerce Platforms

Step 1: Acknowledge Receipt

Upon receiving a SAR, the first step is to acknowledge it promptly—ideally within a few days. This reassures the requester and confirms that the request is being processed. It’s also an opportunity to clarify the scope of the request if it’s vague or overly broad.

Acknowledgement emails should include:

• The date the SAR was received
• Expected response timeframe
• Contact details for further queries

Step 2: Verify the Identity of the Requester

Before providing any personal data, the e-commerce platform must verify the identity of the individual making the request. This can be done through matching known credentials (e.g., email address, order history) or requesting official identification documents.

Verifying identity is especially critical when SARs are submitted through third-party platforms or unfamiliar email addresses. It safeguards against fraudulent access to customer data.

Step 3: Locate the Data

Locating personal data is often the most time-consuming part of processing SARs on UK e-commerce platforms. Data may be stored across:

• Customer Relationship Management (CRM) systems
• Order processing tools
• Email marketing software
• Website cookies and analytics platforms
• Customer service systems

A data map or inventory can significantly streamline this step. Businesses should develop procedures for systematically searching all systems where personal data may reside.

Step 4: Review and Compile the Data

Once the relevant data has been located, it must be reviewed carefully. The business should ensure that:

• Only personal data belonging to the requester is included
• Third-party data is redacted unless permission has been granted
• Internal communications are handled appropriately (e.g., staff opinions may need to be excluded or anonymised)

This step requires both technical knowledge and legal oversight to ensure that the response complies with data protection laws.

Step 5: Deliver the Response

The final SAR response must be delivered in a structured, accessible, and secure format. Common formats include PDF files or secure download links. The response should include:

• A summary of the processing activities
• The specific data requested
• Any relevant contextual information

It’s also good practice to explain the data and provide contact details in case of further questions.

Common Challenges in Managing SARs on E-Commerce Platforms

High Volume and Limited Resources

E-commerce platforms can receive dozens of SARs per month, especially during peak trading periods. Small businesses may struggle with resource allocation, while larger organisations may face coordination issues between departments. Automating parts of the SAR process can help reduce the burden.

Inconsistent Data Practices

Without standardised data collection and storage procedures, locating and compiling personal data becomes more difficult. Businesses should implement consistent practices to better manage SARs on UK e-commerce platforms, particularly as data continues to accumulate.

Technical and Security Issues

Providing data securely is as important as responding quickly. Data breaches during the SAR process can result in serious consequences. Secure portals, encrypted emails, and user authentication can mitigate these risks.

How to Prepare Your E-Commerce Platform for SARs

Conduct a Data Audit

Knowing where and how data is stored is the first step in handling SARs effectively. Conducting a data audit allows businesses to map data flows, identify storage locations, and classify information. This process is critical to developing a repeatable SAR workflow.

Train Staff and Appoint Data Champions

Anyone who may handle SARs—from customer service to IT—should receive regular training on data protection obligations. Larger businesses may benefit from appointing dedicated data champions who can coordinate responses and ensure ongoing compliance.

Develop a SAR Policy and Workflow

A documented SAR policy can serve as a reference for all staff. It should outline how to receive, verify, process, and respond to requests. Including templated emails and response formats can also speed up processing time.

Use Technology to Streamline Compliance

There are several tools available that can support the efficient handling of SARs on UK e-commerce platforms. These include:

• Data discovery and mapping software
• Secure communication platforms
• Automated redaction tools
• Workflow management systems

Investing in the right technology can reduce costs, minimise errors, and improve response times.

Regulatory Risks and Consequences of Non-Compliance

Financial Penalties

The Information Commissioner’s Office (ICO) can issue fines for non-compliance with SAR requirements. These fines can reach up to £17.5 million or 4% of global annual turnover—whichever is higher.

Reputational Damage

Failing to handle SARs properly can lead to consumer complaints, negative publicity, and loss of trust. In today’s competitive e-commerce environment, trust is a key differentiator, and mishandling personal data can have long-term business impacts.

ICO Investigations and Audits

Repeated failures or serious lapses in data handling can trigger audits or investigations by the ICO. These proceedings can be resource-intensive and disruptive, even if no fines are issued.

Συμπέρασμα

Handling SARs on UK e-commerce platforms is no longer just a regulatory checkbox—it is a reflection of a business’s commitment to transparency, accountability, and respect for customer rights. As awareness of data protection grows, more consumers are exercising their rights, and businesses must be ready to respond confidently and competently.

By establishing clear policies, training staff, leveraging technology, and maintaining secure data practices, e-commerce businesses can not only meet their legal obligations but also strengthen customer relationships in a data-conscious era.

Preparation today ensures protection tomorrow. Prioritising your SAR strategy now will keep your platform compliant, competitive, and trusted in an increasingly regulated digital world.