What they're telling people is actually rather phoney. You don't have to email anyone in particular to get a subject access request. You don't even need to be specific about what you want (exam marks) - you could just say I am making a subject access request. Then they would have to send you everything they have on you in 30 days.
Haven't you actuarial professionals been through such training yourselves? You could receive such an email, and if you've undergone such training then you know it's your duty to forward such emails to your data protection officer or whoever it is that deals with this. It doesn't mean the clock ticks from when they get it but rather from when your employer receives it i.e. your inbox. It is not down to the requester to email the correct person.
We all know, or should know, that this is how 'corporate lawyers' would like us to behave, putting hurdles up that don't exist so that their failing & unlawful conduct can be 'defended' but from what I've seen IFoA lawyers don't make, or interpret, the law. Therefore I would prefer it if IFoA were more accurate and said they welcomed subject access requests to any member of staff but that they preferred it sent to that email address.
I would additionally recommend members ask in addition to exam marks to specifically request any note, alert note, pop up note, that IFoA hold in order to instruct staff to treat you differently to other members. IFoA do hold such notes, they have failed to show such notes in subject access requests, unlawfully so in the view of the Information Commissioner's Office, so make sure you know exactly what they hold about you...
Last edited by a moderator: Dec 15, 2018