I am not qualified, nor am I an expert on legal matters. What I have stated here is my own viewpoint and I would strongly suggest that you study the DPA yourself to confirm such issues, and that you clarify your situation with the IC who can be contacted on 01625-545700. The IC are very helpful to consumers and their advice on the DPA is pretty good as well.(posted 8238 days ago)You can see the DPA at www.hmso.gov.uk/acts/acts1998/19980029.htm
With regard to manual data being provided for a SARN request the DPA states that the second period of transitional relief is from the 24th October 2001 to 23rd October 2007.
During the second period of transitional relief data controllers are able to apply section 8 of the DPA to exclude manual data being provided in response to a SARN, if that manual data was part of a manual data control system created before 24th October 1998, and if the manual data was also created before October 24th 1998.
But, after 24th October 2001 data controllers must suply copies of all manual data and automated data which is not covered by the second period of transitional relief to a data subject in response to a SARN request.
Good luck.