Yes. Even if an individual’s personal information was recorded many years before Part X came into force in January 2020, they have a right to access their record and you must protect it against privacy breaches.
However, Part X does not apply retroactively. For example, an individual would not have a right to complain to the IPC about a privacy breach that happened — or an access request they submitted— years before Part X came into force.
Learn more in the guide to Part X
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