Investigation reports, Inter company disputes and subject access requests – How do I handle it?

There is a growing occurrence of inter-company disputes and the use of subject access requests to elicit sensitive information. Take the following scenario as an example:

Bravo Limited and Charlie Limited form a business partnership and work closely together. However, they are distinct and separate legal entities.

A complaint of bullying/harassment is made by an employee of Bravo Limited (the “Complainant”) against employee of Charlie Limited (the “Accused Employee”).

1. On foot of the complaint, Charlie Limited conducts a full investigation in line with its own internal employee policies and procedures. They also utilise a third-party investigator to ensure independence given the