Is it similar to the distinction in the USA between a FOIA request and one made under the Privacy Act?

Corollary: what is the origin of the Subject Access Request system, and why does the name seem to be shared by other European countries?

Corollary 2: did the legal phrase Freedom Of Information first come to be used in the US or the UK, or even elsewhere?

1 Answer 1


There are two main differences between a SAR and a FOI request. A subject access request is about your personal data held by any organization, whereas a freedom of information request is a more general one about information held by government organizations.

Example SAR: I'd like to see my credit file.

Example FOI: I'd like to see the report saying that 'project X' was expected to go $2 million over budget and 90% likely to fail.

The subject access request comes from European law: currently the General Data Protection Regulation but was also found in predecessors.

The modern Freedom of Information principles come largely from the USA, as a reaction to the idea that government had become less accountable during the cold war era. As such I think most people would regard the US act as a landmark, although it's not exactly the first.

  • What types of information can be omitted from responses to a subject access request, and can the perceived intentions of the filer in submitting it be taken into account when deciding whether to grant or refuse it?
    – Jackie FJA
    Oct 12, 2020 at 12:21
  • FOIA can be denied based on "this is confidential for state security reasons"
    – Trish
    Oct 12, 2020 at 13:14

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