united-states united-kingdom european-union freedom-of-information
How does a subject access request differ from a freedom of information request?
<p>Is it similar to the distinction in the USA between a FOIA request and one made under the Privacy Act?</p>
<p>Corollary: what is the origin of the Subject Access Request system, and why does the name seem to be shared by other European countries?</p>
<p>Corollary 2: did the legal phrase Freedom Of Information first come to be used in the US or the UK, or even elsewhere?</p>

<p>There are two main differences between a SAR and a FOI request. A subject access request is about your personal data held by any organization, whereas a freedom of information request is a more general one about information held by government organizations.</p>
<p>Example SAR: I'd like to see my credit file.</p>
<p>Example FOI: I'd like to see the report saying that 'project X' was expected to go $2 million over budget and 90% likely to fail.</p>
<p>The subject access request comes from European law: currently the General Data Protection Regulation but was also found in predecessors.</p>
<p>The modern Freedom of Information principles come largely from the USA, as a reaction to the idea that government had become less accountable during the cold war era. As such I think most people would regard the <a href="https://unredacted.com/2018/04/17/john-moss-and-the-roots-of-the-freedom-of-information-act-worldwide-implications/" rel="nofollow noreferrer">US act</a> as a landmark, although it's not exactly the first.</p>
