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Making a request does not require the person to create an account where they do not already hold one.

Intent

Making a person create an account puts a barrier before a right they already hold, and 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.

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