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I am in the process of trying to submit a SAR (Subject Access Request) to UK Visas and Immigration (UKVI), but, I have read this paragraph:

your signature and the date, within the last 6 months – please note your signature as well as your photo identification is used to verify that the person making the request is entitled to do so

However, I have radically changed my signature since the last time I had to pass through UK Immigration (which is the last record they have on file of me).

Would a DPO (Data Protection Officer) be able to reject my request on the basis that my signature is not at all what they have on file? (My photography is still recognizable from the one on their record though.)

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    Is there a particular reason you don't want to just use your old signature for this?
    – Richard
    May 30, 2022 at 14:49
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    I would like to not be using the old one for specific reasons, yes @Richard
    – Nicolas Formichella
    May 30, 2022 at 14:51
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    Because biting your tongue and using the old signature would be far and away the easiest solution, I mean. Even if it's for whatever reason unpalatable.
    – Richard
    May 30, 2022 at 14:53

2 Answers 2

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The law, at section 52(4) Data Protection Act 2018 does not expressly require a signature. What is needed is confirmation of one's identity:

Where the controller has reasonable doubts about the identity of an individual making a request under section 45, 46 or 47, the controller may—

  • (a) request the provision of additional information to enable the controller to confirm the identity, and

  • (b) delay dealing with the request until the identity is confirmed.

One option is to submit the request with an explanation as to why your signature has changed and wait and see if the data controller comes back for additional information.

If you can't provide anything more, or they still won't process your request if you do, there's alway the option of appealing to the Information Commissioner's Office

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If you're unable to reproduce your signature due to some disability (e.g. tremors due to Parkinson's, or amputation of your dominant hand), I'm sure that you can contact the data protection officer to find alternative means of identity verification.

Otherwise, things don't look so good. If there is a reasonable security measure, and you try to circumvent that security measure, that's quite suspicious. Someone who just prefers to not provide a signature is indistinguishable from an unauthorized requester who is unable to forge the signature.

You can of course ask for which purpose this signature is used. It might be used for potential comparison with existing signatures, but maybe it is just part of a written affirmation that you are the data subject.

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