A Generic Data Model for Implementing Right of Access Requests.

According to Article 15 of the GDPR, data subjects have the right to access personal data handled by data controllers and their processors. This raises demand for a dedicated technical service implementation in order to create valid, complete, and legally compliant responses to such requests. In this paper, we provide both a Data Request Model and a Response Data Model for answering such requests on a technical level. While outlining the overall process of handling such a request, we showcase a set of requirements that needs to be fulfilled, and we discuss a set of issues commonly arising in such an Article 15 service implementation.