No Account Required
Making a request does not require creating an account where the person does not already hold one.
Intent
Requiring a person to create an account adds a barrier to a right they already hold, and usually collects more data than the request needs.
How to test it
An assessor scores the criterion against a single response:
- Score 2
- A person can make a request without creating an account, unless they already hold one.
- Score 1
- An account is not required outright, but the only signposted route runs through one.
- Score 0
- The person must create an account before they can make a request.
The law it reflects
This criterion reflects Article 12(2) of the UK GDPR. That mapping is a guide, not a legal test: conformance is judged against the criterion, not the article.
See A3 in context in the full standard.