The ICO says:

“The GDPR includes a right for individuals to have inaccurate personal data rectified, or completed if it is incomplete. An individual can make a request for rectification verbally or in writing. You have one calendar month to respond to a request.”

Any inaccurate data held on a person record can be corrected by editing their record in Adapt.

Currently, users cannot modify journal notes in Adapt, but this requirement means that if there is inaccurate data or disputed opinions in Journal Notes, the user needs to be able to correct these. Therefore, selected users can now edit journal notes in Adapt.
Users will need to have this feature switched on through their Adapt profile. Please contact your Erecruit representative to request this.

Note: These areas should be accurate, as Individuals now have the right to see these comments and contest them. Changes should not be made as a result of a Subject Access Request. 

Agencies may choose to edit journal notes to protect the rights of ‘Other’ individuals. For instance, if they receive a Subject Access Request from a person and their reference or journal notes contains contact details of others, these should not be visible to them in the portal. In this example, Agencies can redact this information or move it to the Confidential folder.

To edit Journal Notes, use the pencil icon:

Use curly brackets {John} to replace the text between the brackets with {...}
Once completed, click OK to update.

Important - If a modification is made on journal notes, the time, date and user of the modification will be recorded. If this is done after a Subject Access Request, it will show the Individual that something was modified after their request.

Note: If an individual is contesting the accuracy of their data, they have the right to request restriction of the processing of their personal data whilst it is being checked. Therefore, the user may want to run the Restrict Processing workflow on this Individual until it is resolved.

Where personal data of an Individual has been rectified, the ICO states:

“If you have disclosed the personal data to others, you must contact each recipient and inform them of the rectification or completion of the personal data”.

This may mean that Agencies need to let their Clients (or any third parties) know about the change in data processing for these individuals.

Did this answer your question?