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Date: 19/01/2026
Objective Report – Formal Complaint Submitted to the Solicitors Regulation Authority (SRA)
1. Purpose of the Report
This page provides a neutral and factual summary of the formal complaint submitted on 20 October 2025 to the Solicitors Regulation Authority (SRA) regarding the conduct of Stephen Rimmer LLP (Firm No. OC340622) in relation to a Subject Access Request (SAR).
For reasons of transparency and to ensure an accurate reconstruction of the events, the full PDF of the complaint is published on this page, as it forms an essential component of the documentary record.
For reasons of transparency and to ensure an accurate reconstruction of the events, the full PDF of the complaint is published on this page, as it forms an essential component of the documentary record.
2. Background and Chronology
- 27 August 2025 – A SAR was submitted to the Firm and associated parties under UK GDPR and the Data Protection Act 2018.
- 30 September 2025 – The Firm responded, stating that processing was suspended pending receipt of identification “certified by an Italian Solicitor”, due to the complainant’s residence in Italy.
- 1 October 2025 – The complainant clarified that no such professional category exists under Italian law and proposed an alternative form of certification compliant with D.P.R. 445/2000.
- At the time of the complaint, no disclosure had been provided and the Firm had not indicated the date on which the SAR was received.
3. Issues Raised in the Complaint
a) Data Protection Compliance
The complaint identifies:
- a delay exceeding the statutory one‑month deadline;
- the absence of a stated SAR receipt date;
- an identity‑verification requirement considered incompatible with Italian law.
These elements are presented as potentially inconsistent with UK GDPR transparency obligations and SRA regulatory standards.
b) Professional Competence and Service Standards
The complaint notes:
- the reference to an “Italian Solicitor”, a role not recognised within the Italian legal system;
- the possible creation of unnecessary procedural barriers;
- concerns relating to SRA Principles on integrity and quality of service.
c) Cross‑Border Considerations
The complaint states that:
- the Firm’s instruction may amount to activity not recognised under Italian jurisdiction;
- reference is made to Article 348 of the Italian Criminal Code (unauthorised practice), while acknowledging that this lies outside the SRA’s direct remit;
- the matter raises broader questions regarding cross‑border competence.
4. Declared Impact
The complainant reports:
- procedural delays;
- uncertainty regarding identity‑verification requirements;
- potential prejudice to data‑subject rights;
- wider implications for public trust in cross‑border data‑protection procedures.
5. Actions Requested from the SRA
The complainant requests that the SRA:
- Conduct a desk‑based review to assess:
- whether the Firm correctly identified its role as data controller;
- whether the identity‑certification instruction was professionally and legally appropriate;
- whether the delay constitutes a breach of SRA Standards and Regulations.
- Consider, if appropriate:
- initiating a formal investigation;
- taking disciplinary action;
- publishing any findings for transparency.
6. Documentation Provided
The complaint lists six attachments, including:
- the original SAR;
- the Firm’s acknowledgement;
- the complainant’s reply;
- a chronology of correspondence;
- legal analysis;
- supporting notes on relevant Italian legislation.
7. Notice of Publication
The original complaint included a notice stating that, in the absence of disclosure or adequate justification, a documented reconstruction of the case would be published using only materials lawfully held by the complainant and in full compliance with UK, EU, and Italian privacy and defamation laws.
As no disclosure was provided within a reasonable timeframe, publication has now taken place.
The notice also indicated that additional material would be released where relevant.
Accordingly, the subsequent correspondence exchanged with the SRA forms part of the material referenced in that notice and is included within the published documentation.
The notice also indicated that additional material would be released where relevant.
Accordingly, the subsequent correspondence exchanged with the SRA forms part of the material referenced in that notice and is included within the published documentation.
The dedicated website referenced in the notice is now active and hosts the relevant records.
8. SRA Automatic Acknowledgement
On 20 October 2025, the SRA issued an automatic acknowledgement indicating:
- an estimated response time of 45 working days;
- guidance on the types of matters typically investigated;
- distinctions between issues appropriate for the SRA, the ICO, or the Legal Ombudsman.
9. SRA Follow‑Up of 12 January 2026
On 12 January 2026, Investigation Officer Brandon Lee contacted the complainant requesting further information.
The email referred to matters such as:
The email referred to matters such as:
- the circumstances of a plea;
- inconsistent legal advice;
- an interview conducted without an interpreter.
These elements were not included in the original complaint or its attachments.
10. Complainant’s Reply of 13 January 2026
The complainant responded on 13 January 2026, stating that:
- the matters referenced in the SRA’s request were not part of the original submission;
- the SRA’s reply did not address the issues actually raised;
- it was unclear whether the six attachments had been reviewed;
- the material had since been published, as previously notified;
- the matter now forms part of ongoing proceedings within the Italian jurisdiction;
- no further clarification could be provided beyond the original submission.
Conclusion
This page provides an objective summary of the formal complaint submitted to the SRA regarding the handling of a SAR by Stephen Rimmer LLP.
The full PDF is published here as an essential component of the factual record, ensuring transparency and enabling a complete reconstruction of the events.
The full PDF is published here as an essential component of the factual record, ensuring transparency and enabling a complete reconstruction of the events.
Procedural Closure – Status Recorded
This notification was formally issued to all relevant entities, who were offered the opportunity to provide clarifications or counter‑documentation. As of the present date 21 February 2026, no objections, corrections, or alternative factual reconstructions have been submitted. The notification phase is therefore considered procedurally closed. A right of reply remains available, but any late submissions will not alter the factual framework established during the notification period.
The Record Speaks
