Balancing GDPR access rights has become challenging for controllers, particularly regarding the right of access versus competing rights, such as third-party privacy. Article 15(3) GDPR grants individuals access to their personal data, but Article 15(4) allows limitations if it affects others' rights. The EDPB provides guidelines emphasizing a case-by-case assessment to weigh rights and justify access limitations. The DPC recently highlighted that restrictions should be evidence-based, particularly in sensitive situations. Controllers must document decisions effectively and seek legal advice to navigate potential risks while adhering to GDPR.
https://www.arthurcox.com/knowledge/balancing-gdpr-data-access-rights-against-the-rights-of-others/