CHAPTER 11: REQUESTS MADE BY ONE PERSON ON BEHALF OF ANOTHER
Anyone can make a freedom of information request. There should never be any question of someone making a request on behalf of someone else: they may as well just make the request in their own right and share the response with the other person.
However, the Data Protection Act is different, because a subject access request asks for information about the data subject themselves. In most cases the data subject will be able to make the request directly. However, they don’t have to: someone else may be entitled to act on their behalf, they can ask someone else to act on their behalf, or it may be more appropriate for someone else to act on their behalf.
The person acting on behalf of the ...