No Barrier to Collection
Receiving the response does not require creating an account where the person does not already hold one, or using one particular portal.
Intent
A portal that the person has to join in order to collect their data adds an account, and a barrier, at the last step.
How to test it
An assessor scores the criterion against a single response:
- Score 2
- The person could collect the response without creating an account or using one particular portal.
- Score 1
- The response was delivered through a portal, but the person could ask for another way and get it.
- Score 0
- Collecting the response required creating an account, or using one portal with no alternative.
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 G5 in context in the full standard.