Data accuracy is about whether personal data is correct and not misleading as to fact; disagreement with an opinion or decision is not automatically an accuracy breach.
A wrong date of birth, balance, account status or event date can be factual inaccuracy. A clinician’s opinion, risk assessment or complaint conclusion may be a genuinely held opinion even if you strongly disagree.
The record can still be inaccurate if it falsely presents an opinion as fact, attributes it to the wrong person, omits necessary context or records the underlying facts incorrectly.
Key points
- Identify the exact data item.
- Classify it as fact, opinion, inference or decision.
- For factual errors, provide correction evidence.
- For disputed opinions, consider whether the record accurately records the opinion and your challenge.
- Look at downstream sharing and consequences.
Examples
| “DOB: 01/01/1950” when documentary evidence shows 1994 | Factual accuracy issue. |
|---|---|
| “Advisor believed the customer was vulnerable” | Potentially an opinion/inference; ask whether attribution/context is accurate. |
| “Account defaulted on 25 March” | Can be factual reporting status/timing issue requiring underlying account history. |
| “Complaint not upheld” | A decision; disagreement alone is not data inaccuracy. |
Why context matters
Accurate data must also not be misleading. A fragment can be technically true but misleading if material context is omitted, depending on how it is processed and presented.
Opinions can still contain inaccurate factual building blocks
The fact that a record is an opinion does not make every statement inside it immune from correction. A complaint conclusion may be an opinion, while the date, balance, address or event it relies upon may be objectively wrong. Separate the evaluative judgment from its factual premises and challenge the inaccurate premise precisely.
Sometimes the remedy is annotation rather than deletion
Where an organisation is entitled to retain a genuinely held professional opinion, the appropriate outcome may be to add the consumer’s challenge, correct factual elements or record that the matter is disputed rather than erase the whole record. The right remedy depends on what is inaccurate and why the organisation needs the record.
In practice
- Quote the exact data, not “my file is wrong”.
- Attach evidence of the correct fact.
- Ask for rectification and, where applicable, notification to recipients.
- Separate data correction from an appeal against a decision on the actual complaint.
What to do
A practical next-step plan
- Identify data item.
- Classify fact/opinion.
- Provide evidence.
- Request correction/context.
- Challenge unresolved handling to ICO.
Common traps
Things that often confuse the issue
- Demanding deletion of every negative opinion.
- Failing to identify what data is inaccurate.
Official sources
Check the rules behind this guide
This distinction is especially important in data-protection disputes: a record can be accurate as a record of an opinion or decision even where you strongly disagree with that opinion or decision. The factual data inside it may still be challengeable if it is wrong.
These are official or primary sources for this topic. Rules, scheme terms and deadlines can change, so check the live source before relying on a formal time limit or procedure.