Right to rectification

Accuracy depends on what the record claims

A rectification request can be verbal or written and does not need a formal label. A wrong address, start date or qualification may need correction. An incomplete record may need a supplementary statement when extra context is necessary for it to be accurate.

Opinions need a more careful test. An opinion is not inaccurate merely because the employee disagrees, but the record should make clear that it is an opinion, who expressed it and what evidence informed it. The person's disagreement may itself need to be recorded.

Check the point rather than defending the file

The ICO's rectification guidance says organisations should take reasonable steps to check accuracy, considering the nature of the data and why it is used. Ask for evidence only where it is genuinely needed and proportionate.

Restrict processing while accuracy is being verified when the person requests it and the conditions apply. Mark the record so a disputed item is not silently used for payroll, performance or another decision before the check is complete.

Close the loop across recipients

Respond within the applicable deadline. If the request succeeds, correct or complete the data and tell recipients where required. If the organisation concludes that the record is accurate, explain the decision and the routes to complain or seek a remedy.

Keep a proportionate audit record of the request, evidence considered, systems changed, recipients notified and response. The purpose is to show the correction was handled, not to retain an unrestricted duplicate of disputed personal information.