Identity Verification for Privacy Requests: What's Required, What's Overkill

Before you hand over, correct, or delete someone's data, you have to be sure they are who they say they are. Get verification wrong in one direction and you disclose data to an impostor; get it wrong in the other and you build so much friction that legitimate requests stall or you collect more data than the request itself. The goal is to match the rigor to the risk.

Why Verification Matters

A data subject request is a lever. An attacker who can pass your verification can use an access request to harvest someone's data, or a deletion request to erase it. Regulators expect reasonable verification precisely because the rights are powerful. At the same time, the law does not want verification used as a barrier, and it warns against collecting new personal data just to verify a request.

Calibrate to Sensitivity and Action

Not every request needs the same proof:

• Low sensitivity, low risk (for example, a simple opt-out): often verifiable by confirming control of the email or account the request came from.
• Access to personal data: a higher bar, since the payoff to an impostor is the data itself. Confirm control of the account and, where warranted, a second signal.
• Deletion or correction: high stakes, because the action is destructive or alters records. Verify carefully, and consider a confirmation step before acting.

Tie the check to what the person is asking for, not a single maximum-friction process applied to everyone.

Common Mistakes

• Over-collecting. Do not demand a government ID for a routine opt-out. Asking for more data to process a privacy request is the opposite of the point.
• Under-verifying destructive actions. Deletion should never be easier to trigger than access.
• Letting verification eat the clock. In most laws the response deadline starts when the request arrives, so slow verification shortens the window you have to actually respond.

How Concord Fits

Concord Privacy includes an identity-verification step in the request workflow, so you can require the right level of proof for the request type before the work begins, then move a verified request straight into locating and acting on the data.