Dsar Response

Codex v1 local-input note: This migrated skill supports local files and pasted text by default. References to Drive, CLM IDs, Slack, Westlaw, iManage, Ironclad, eDiscovery, dockets, or other remote systems require a separately configured Codex connector/MCP server. When a connector is unavailable, ask for a local export, local file path, or pasted excerpts. If config/local/codex-for-legal/<practice>/CLAUDE.md is missing, ask the user to run the relevant cold-start-interview or customize skill and copy from config/templates/codex-for-legal/<practice>/CLAUDE.md.

$privacy-legal:dsar-response

1. Load config/local/codex-for-legal/privacy-legal/CLAUDE.md → DSAR process (systems list, verification method, SLA).
2. Run the workflow below.
3. Classify request type. Check escalation triggers — if any fire, route before proceeding.
4. Walk through: verify identity → walk systems list → exemption analysis → draft.
5. Output response draft. Do NOT send — human reviews and sends.
6. Log the DSAR per house process.

Before pasting the request: the request will contain the data subject's PII. Confirm your session and output storage meet your data-handling requirements. Redact anything you don't need (ID attachments, unrelated email threads). Do not store the subject's name in filenames.

$privacy-legal:dsar-response
[paste the request email]

DSAR Response Drafting

Matter context

Matter context. Check ## Matter workspaces in the practice-level CLAUDE.md. If Enabled is ✗ (the default for in-house users), skip the rest of this paragraph — skills use practice-level context and the matter machinery is invisible. If enabled and there is no active matter, ask: "Which matter is this for? Run $privacy-legal:matter-workspace switch <slug> or say practice-level." Load the active matter's matter.md for matter-specific context and overrides. Write outputs to the matter folder at config/local/codex-for-legal/privacy-legal/matters/<matter-slug>/. Never read another matter's files unless Cross-matter context is on.

Purpose

A DSAR has a deadline (set by the applicable regime), a process (verify, locate, assess exemptions, respond), and a bunch of places it can go wrong. This skill walks through each step and drafts the response.

Jurisdiction assumption

This analysis assumes the jurisdictional scope specified in your configuration. Privacy rules, response deadlines, and lawful bases vary materially by jurisdiction (GDPR vs. state consumer privacy laws vs. sectoral). If the data subject, processing activity, or controller is in a different jurisdiction than configured, this analysis may not apply as written.

Load the process

Read config/local/codex-for-legal/privacy-legal/CLAUDE.md → ## DSAR process. That section has:

• The systems list (every place user data lives)
• Identity verification method
• Response SLA
• Who handles routine vs. who gets escalated

If the systems list is empty or stale, flag it — can't do a complete DSAR without knowing where to look.

Workflow

Step 1: Classify the request

Identify which right the data subject is invoking. Common categories:

• Access — copy of their data + information about processing
• Deletion / erasure — remove their data (subject to exemptions)
• Portability — their data in machine-readable format
• Correction / rectification — fix inaccurate data
• Objection — stop a particular processing (often marketing)
• Restriction — pause processing pending a dispute
• Opt-out of sale/share / automated decision-making — regime-specific rights

Research the applicable rule before proceeding. For each invoked right, identify the jurisdiction(s) whose law applies (GDPR, UK GDPR, CCPA/CPRA, other US state privacy laws, sectoral regimes). Cite the controlling statute or regulation with pinpoint references — the specific article/section, the scope of the right, any carve-outs. Note effective dates; data subject rights are amended frequently (new state laws each legislative session). Flag uncertainty and escalate for attorney verification rather than stating a rule you haven't confirmed.

No silent supplement. If a research query to the configured legal research tool returns few or no results for the jurisdiction's rights, exemptions, or deadlines, report what was found and stop. Do NOT fill the gap from web search or model knowledge without asking. Say: "The search returned [N] results from [tool]. Coverage appears thin for [regime / right]. Options: (1) broaden the search query, (2) try a different research tool, (3) search the web — results will be tagged [web search — verify] and should be checked against a primary source before relying, or (4) flag as unverified and stop. Which would you like?" A lawyer decides whether to accept lower-confidence sources.

Source attribution tiering. Tag every citation with its source. For model-knowledge citations, use one of three tiers rather than a single blanket "verify" tag:

• [settled] — stable, well-known statutory and regulatory references unlikely to have changed (e.g., GDPR Art. 33, CCPA § 1798.100, FTC Act § 5, 45-day CCPA response window under § 1798.130(a)(2) as a concept). Still verify before filing, but lower priority.
• [verify] — model-knowledge citations that are real but should be verified: specific implementing regulations, agency guidance, case holdings, thresholds, effective dates, post-2023 amendments.
• [verify-pinpoint] — pinpoint citations (specific subsection letters, volume/page numbers, paragraph numbers, regulatory subpart references) carry the highest fabrication risk and should ALWAYS be verified against a primary source.

Tool-retrieved citations keep their source tag ([Westlaw (connector optional; not enabled in v1)], [issuing authority site], or the MCP tool name); web-search citations remain [web search — verify]; user-supplied citations remain [user provided]. The tiering surfaces the real verification work — a reader who verifies everything verifies nothing. Never strip or collapse the tags.

Some requests are combinations — "delete my account and send me my data first" is deletion + portability. Handle as two linked requests.

Step 2: Verify identity

Per the method in config/local/codex-for-legal/privacy-legal/CLAUDE.md. Common approaches:

• Logged-in verification: Request came from within an authenticated session → identity confirmed
• Email match: Request came from an email on file → usually sufficient for low-risk requests
• Additional verification: For high-value accounts or deletion requests → challenge question, phone verification, ID document

Calibrate to risk. Over-verifying turns the DSAR process into a barrier (bad look with regulators). Under-verifying risks handing someone else's data to a fraudster.

If identity can't be verified:

We were unable to verify that this request came from the individual whose data
is at issue. To proceed, please [verification step]. We cannot provide personal
data in response to a request we cannot verify.

This pauses the clock (arguably) but don't sit on it — respond to say you need verification within a few days, not on day 29.

Step 3: Locate the data

Walk the systems list from config/local/codex-for-legal/privacy-legal/CLAUDE.md. For each system:

For a B2B processor: the "data subject" is usually your customer's end user. Check whether this is actually your customer's DSAR to handle, not yours. Many processor DPAs say "forward DSARs to the controller."

Step 4: Exemption analysis

Not everything gets produced or deleted. Research the applicable rule before proceeding. For each item, identify every exemption that plausibly applies under the regime in scope (e.g., third-party privacy, privilege, trade secret, security, legal obligation to retain, establishment/defense of legal claims, transactional necessity, backup rotation accommodations, freedom of expression). Cite the controlling statute, regulation, or case with a pinpoint cite. Exemption scope varies by jurisdiction and regime — verify currency and flag uncertainty.

Don't narrow the list on a subjective call. The skill proposes exemptions where a good-faith basis exists and flags the uncertain ones; the attorney narrows the list before the response goes out. Dropping an exemption that later turns out to apply is costly — once material is disclosed, the exemption is functionally gone. Over-asserting a plausible exemption is correctable by the attorney in review. Prefer the recoverable error.

Every proposed exemption carries an explicit note: "proposed — requires attorney review before asserting. Regulators scrutinize blanket exemption claims, so the attorney narrows this list; the skill does not."

Common recurring questions to work through:

• Does the record contain data about other people that needs to be redacted before production?
• Is there a specific legal retention obligation that blocks deletion? Cite it.
• Is there an active litigation hold covering this individual's data?
• Are there backup rotation or technical-feasibility accommodations that need to be documented (not used as a general excuse)?

Document every exemption claimed. If a regulator asks why you didn't delete something, "we had a legal obligation" needs a citation.

Step 5: Draft the response — TWO LETTERS

Research-connector pre-flight. Before emitting either letter or the internal exemption analysis, check whether a legal research connector is reachable for this session — Westlaw (connector optional; not enabled in v1), an EUR-Lex / regulator-site connector, or any firm-configured research MCP. Collect this into the reviewer note per CLAUDE.md ## Outputs — the reviewer note sits on the INTERNAL exemption-analysis and cover memo, NOT on the outward-facing DSAR letters to the data subject. If no connector returns results in Step 1 (right classification), Step 4 (exemption analysis), or the Deadline management research step (or none is configured at run time), record it in the Sources: line of the internal reviewer note — e.g., not connected — cites from training knowledge; claimed exemptions, response deadlines, and extension mechanisms are especially fabrication-prone, verify before asserting any exemption to a data subject or regulator. Per-citation [model knowledge — verify] tags remain inline. Do not emit a standalone banner above the output.

Most regimes expect (or require) a prompt acknowledgment separate from the substantive response. Produce both; do not collapse them into one letter that waits until the 45-day deadline to go out.

• Step 5a — Acknowledgment letter. Sent within days of receipt (target: same-day to 3–5 days, always well inside the regime's statutory window). Confirms receipt, states what the controller understands the request to be, states the response clock and the target date, asks for any identity-verification material still outstanding. Does NOT contain the substantive disclosure. A prompt acknowledgment is the first regulator-visible signal that the DSAR process is working; it also reduces the risk of a duplicate request or an early complaint.
• Step 5b — Substantive response letter. The actual disclosure, deletion confirmation, or portability export. Goes out by the statutory deadline (or the internal SLA if tighter). Only after identity verification is complete and the Step 3 / Step 4 data location + exemption analysis is done.

Before proceeding to send either letter to the data subject: Read ## Who's using this in config/local/codex-for-legal/privacy-legal/CLAUDE.md. If the Role is Non-lawyer:

Sending a DSAR response has legal consequences — the content, the exemptions claimed, and the omissions are all reviewable by a regulator, and misstatements become enforcement exposure. Have you reviewed this with an attorney? If yes, proceed. If no, here's a brief to bring to them:

[Generate a 1-page summary: data subject, right invoked, applicable regime(s), what was located across the systems list, what is being withheld and under which exemption, identity verification posture, response deadline, and the three things to ask the attorney before the letter goes out.]

If you need to find a licensed attorney, solicitor, barrister, or other authorised legal professional in your jurisdiction: your professional regulator's referral service is the fastest starting point (state bar in the US, SRA/Bar Standards Board in England & Wales, Law Society in Scotland/NI/Ireland/Canada/Australia, or your jurisdiction's equivalent).

Do not proceed past this gate without an explicit yes.

Note: Both DSAR letters are externally-facing deliverables sent to the data subject. Do not include the work-product header from config/local/codex-for-legal/privacy-legal/CLAUDE.md ## Outputs on either letter. Internal notes, logs, and exemption analyses that accompany the letters are attorney work product — keep those separate and prepend the work-product header per config/local/codex-for-legal/privacy-legal/CLAUDE.md ## Outputs (which differs by user role — see ## Who's using this).

Before sending either letter: This is a draft for attorney review, not a response to send. Sending commits the controller to a position, may waive exemptions, and may start a regulator's clock. A licensed attorney reviews, edits, and approves before either letter goes to the data subject. Do not send unreviewed.

Step 5a — Acknowledgment letter template

Subject: We received your privacy request — [Company] — [date]

Dear [Name],

We received your [access / deletion / portability / correction] request on [date received].

**Your request, as we understand it:** [one-sentence restatement — e.g., "a copy of all personal data we hold associated with your account, along with the categories of third parties with whom we share it, and deletion of your account after we provide the copy."]

**What happens next:**
- Our target date for the substantive response is [date — no later than the regime's statutory deadline; use internal SLA if tighter]. [If identity verification is outstanding: "We need [specific verification step] before we can proceed — see below."]
- If we need more time because the request is complex or we receive other requests from you at the same time, we will tell you before the initial deadline and explain why. [If the regime allows an extension, cite the controlling provision.]
- No fee applies to this request. [Or: the fee applies only if the regime permits it and the request is manifestly unfounded or excessive — cite the provision.]

[If identity verification is outstanding:]
**To verify your identity,** please [specific verification step — e.g., reply to this email from the address on file with the last 4 digits of the payment method we have on file]. This does not pause our deadline; we continue to work in parallel.

If you have questions, contact [privacy contact].

[Sender]

Clock-start rule. The response clock starts on receipt of the request, not on completion of identity verification — unless the applicable regime says otherwise. Do not tacitly toll the clock on verification. If a regime has a different trigger, cite it; do not assume.

Step 5b — Substantive response letter templates

Access request response:

Subject: Your Data Access Request — [Company] — [date]

We received your request on [date] for a copy of the personal data we hold about you.

**What we found:**

We hold the following categories of personal data associated with [identifier]:

| Category | Source | Purpose | Retained until |
|---|---|---|---|
| [Account info: name, email] | You, at signup | Account management | Account deletion |
| [Usage data] | Our service | Analytics, product improvement | [period] |
| [Support correspondence] | You | Customer support | [period] |

**Your data is attached** in [format]. [Secure delivery note — password-protected
archive, secure link with expiry, etc.]

**Third parties:** We share data with the following processors: [list or link to
subprocessor page].

**Your other rights:** You may also request [deletion / correction / portability].
To do so, [method].

**Data we did not include:**
- [Category] — [exemption and reason, e.g., "internal security logs — disclosure
  would compromise security measures"]
- [Data about other individuals has been redacted from support correspondence]

If you have questions about this response, contact [privacy contact].

Deletion request response:

Subject: Your Deletion Request — [Company] — [date]

We received your request on [date] to delete the personal data we hold about you.

**What we deleted:**

| Category | System | Deleted on |
|---|---|---|
| [Account and profile] | Production | [date] |
| [Analytics events] | [Amplitude/etc.] | [date] |
| [etc.] | | |

**What we retained and why:**

| Category | Reason | Retained until |
|---|---|---|
| [Transaction records] | Legal obligation (tax record retention, [cite law]) | [date] |
| [Backup snapshots] | Will be deleted on next rotation | [date] |

**Third-party processors:** We have instructed [list] to delete your data from
their systems.

Your account is now closed. If you have questions, contact [privacy contact].

Step 6: Log it

DSARs get audited. Record:

• Date received
• Date identity verified
• Date responded
• What was produced/deleted
• Exemptions claimed and basis
• Who handled it

If your team uses a DSAR tracking tool, create the record there. If not, a log file works.

Escalation triggers

Per config/local/codex-for-legal/privacy-legal/CLAUDE.md → Escalation table, escalate when:

• Requester is (or might be) a plaintiff, opposing counsel, or journalist
• Request scope is unusual ("all data including internal communications about me")
• There's a litigation hold on this individual's data (deletion request + lit hold = conflict, lawyer decides)
• Requester is disputing a previous DSAR response
• Any regulator is cc'd or mentioned

Deadline management

Two-letter rule. Every DSAR produces an acknowledgment letter (prompt — target same-day to 3–5 days after receipt) AND a substantive response letter (by the statutory deadline). Most regimes either require or expect a prompt acknowledgment separate from the substantive response; a single combined letter sent on day 45 is a process failure even if it is substantively correct.

Research the currently operative response deadline for the specific right invoked and the applicable jurisdictions. Check whether an extension mechanism exists, how much extra time it buys, and what notice the data subject must receive to invoke it. Identify when the clock starts (receipt vs. verification vs. some other trigger — default rule is receipt; verify per regime). Cite the controlling statute or regulation with pinpoint references. Note effective dates — data protection response timelines are amended frequently and new state laws introduce their own clocks.

If config/local/codex-for-legal/privacy-legal/CLAUDE.md → ## DSAR process records an internal SLA that is tighter than the legal deadline, use the internal SLA and note the legal backstop.

If you're going to need an extension, send the "we need more time" notice well before the first deadline. Day-of extensions look bad.

What this skill does not do

• It doesn't query systems directly. It walks you through the checklist; a human (or a connected tool) does the actual queries.
• It doesn't make exemption calls on close cases. It flags them for a lawyer.
• It doesn't send the response. Draft, review, human sends.