data-protection-and-journalism-a-guide-for-the-media-draft

Data protection and journalism
In practice
provide the information (or some of it) without undermining your
activities, you should do so.
In practice, this means that when you receive a SAR you will need to give
proper thought to whether you could respond, and how much information
you can provide. If you decide not to comply with the request and the
individual complains about your decision, we may ask you to show that
you considered the request, and to explain why you thought providing the
information would be harmful. As with other areas where the exemption
might apply, you will need to be able to show you have a proper process
for considering requests, and some clear reasons for the decision you
made.
The exemption can apply to SARs made before or after publication of a
story. However, you might find it harder to justify rejecting a SAR made
after publication, as you cannot argue that providing the information will
undermine the story by tipping someone off to a forthcoming publication.
We would therefore always expect you to take the timing of the SAR into
account when considering whether you can respond, even if you have
rejected a similar request in the past. You may still be able to use the
exemption after publication, but only if you can explain why you think
responding would undermine future investigations or publications, or
journalism more generally.
Even if you decide that you cannot provide copies of all the information,
you should still consider whether you can partially comply by providing
some of the information, or a description of the information, or even just
confirming whether or not you hold some information.
Remember that even if you do answer the request, you do not have to
include any information about other people unless they have consented,
or it is reasonable to supply it without their consent. You can generally
redact references to your confidential sources. You should also consider
whether it is reasonable to redact references to anyone else mentioned in
the information.
For detailed information on the right of subject access and general advice
on responding to requests, see our Subject access code of practice.
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