Deadlines & Extensions
GDPR requires timely responses to data subject requests. SAR Portal helps you track and manage deadlines to maintain compliance.
The 30-Day Rule
Under GDPR Article 12, you must respond to requests “without undue delay and in any event within one month of receipt.”
How SAR Portal Calculates Deadlines
- Clock starts when the case is created
- Due date is set to 30 calendar days from creation
- Weekends and holidays count toward the deadline
- If the deadline falls on a weekend/holiday, the last working day before is used
Deadline Tracking Features
Dashboard Indicators
The dashboard shows:
- Overdue Cases - Past deadline (red)
- Due This Week - Approaching deadline (yellow)
- Days Remaining - Countdown on each case
Case List View
Each case displays:
- Due date
- Days remaining badge
- Color-coded urgency indicators
Email Notifications
Configure reminders at:
- 7 days before deadline
- 3 days before deadline
- 1 day before deadline
- On the deadline
- When overdue
Extending Deadlines
GDPR Article 12(3) allows extensions for complex requests.
When You Can Extend
- Complex requests requiring more time
- High volume of requests from the same person
- Requests involving large amounts of data
- Requests requiring coordination with third parties
Extension Limits
- Maximum extension: 2 additional months (60 days)
- Total maximum time: 3 months (90 days)
- Must notify subject within original 30 days
How to Extend
- Open the case
- Click More Actions > Extend Deadline
- Select extension duration
- Enter the reason for extension
- Confirm the extension
The system will:
- Update the due date
- Change status to “Extended”
- Log the extension in the audit trail
- Optionally notify the subject
What to Tell the Subject
When extending, inform the subject of:
- The extension and new deadline
- Reasons for the extension
- Their right to complain to a supervisory authority
Example notification:
“Due to the complexity of your request and the volume of data involved, we require additional time to process it fully. In accordance with GDPR Article 12(3), we are extending the response deadline by [X] days. You should receive our complete response by [new date]. If you have concerns about this extension, you have the right to lodge a complaint with your local data protection authority.”
Pausing the Clock
In some situations, the deadline clock may pause:
When Awaiting Information
If you’ve requested identity verification or clarification from the subject, some jurisdictions allow pausing the clock until they respond.
What Counts as Pausing
- Formal written request for clarification
- Identity verification request
- Request for additional details to locate data
Documenting Pauses
Always document:
- Date you requested information
- What you requested
- Date subject responded
- Adjusted deadline calculation
Missing Deadlines
If you miss a deadline:
Immediate Actions
- Respond as quickly as possible
- Apologize for the delay
- Explain the reason
- Complete the request fully
Risks of Missing Deadlines
- Subject complaints to supervisory authority
- Regulatory investigation
- Potential fines
- Reputational damage
Prevention Strategies
- Set up deadline notifications
- Review dashboard daily
- Prioritize approaching deadlines
- Extend early if needed
Best Practices
Create Cases Immediately
Don’t wait to create a case when you receive a request. The legal clock starts at receipt, not case creation.
Monitor the Dashboard
Make checking the dashboard part of your daily routine. Address approaching deadlines proactively.
Extend Early, Not Late
If you suspect a request will be complex:
- Extend within the first week
- Notify the subject promptly
- Document your reasoning
Document Everything
Keep records of:
- When requests were received
- Any delays in creating cases
- Reasons for extensions
- Communications with subjects
Use Notifications
Configure email notifications to alert the right people:
- Case creators
- Team managers
- Compliance officers
Deadline Calculator
| Scenario | Deadline |
|---|---|
| Standard request | 30 days from receipt |
| Extended (1 month) | 60 days from receipt |
| Extended (2 months) | 90 days from receipt |
| Awaiting info (if clock paused) | 30 days from response |
Remember: These are maximum times. GDPR says respond “without undue delay” - faster is always better.