Privacy regulations, such as the GDPR, CCPA, and UK GDPR, give individuals the right to access their personal data. But these rights can be manipulated. In recent years, a new player has emerged: the privacy troll. These are individuals or groups that exploit data protection laws not for the sake of justice or transparency, but for personal gain, revenge, or competitive sabotage. From disgruntled former employees to opportunistic lawyers and even rival businesses, privacy trolls are utilizing tools like DSARs to promote their agendas. 

So, what does this mean for businesses trying to stay compliant?

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Meet the Trolls

There are different types of privacy trolls, each using specific tactics driven by distinct intentions. 

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1. Employment Disputes
Former, resentful employees may submit DSARs to burden the company with time-consuming searches and responses. They may also choose this approach for financial gain, attempting to pressure the employer into a quick settlement. Some experts in the field claim that many DSARs are used as “fishing expeditions” rather than genuine data requests.

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2. Competitive Sabotage Through Repetitive Requests
Competitors or hostile actors sometimes flood businesses with excessive or unfounded DSARs. Even if rejected, each request must be reviewed and justified, which drains time, budget, and legal resources. This burden often overwhelms the organization and might damage its growth plans. This is the privacy-based version of a DDoS attack. 

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3. The DSAR Lawyers

Some law firms have begun to view privacy-related claims as an opportunity, making data privacy litigation one of the fastest-growing areas of the legal practice. They may actively encourage people to submit DSARs as a first step, looking for inconsistencies or technical missteps they can use to justify a lawsuit. In some cases, firms organize or represent groups of individuals in class action suits, using the threat of regulatory complaints or public exposure as added leverage. 

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Lawmakers Are Catching On

In the UK, Part 3 of the Data Protection Act acknowledged this scenario several years ago, granting companies the right to refuse to respond to a data request that appears unfounded or excessive, provided they can demonstrate the basis for this conclusion. 

California’s Senate Bill 690, which goes into effect in January 2026, directly addresses this issue. It amends the California Invasion of Privacy Act (CIPA) to discourage misuse by requiring that actions be “consistent with a commercial business purpose.” We can see that lawmakers are attempting to strike a balance between legitimate data rights and measures to filter out abuse.

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Are Privacy Trolls Always Bad?

In two words: Not necessarily. While their motives are often questionable, privacy trolls can sometimes serve as an unexpected “stress test” for an organization’s data practices. By triggering DSAR processes or legal scrutiny, they may uncover weak spots that haven’t been addressed, such as disorganized data storage, outdated policies, or inconsistent internal workflows. 

For companies that haven’t fully matured their privacy operations, these confrontations can act as a wake-up call. In that sense, privacy trolls might unintentionally expose issues that, if left unchecked, could lead to regulatory action or reputational harm down the line. Of course, waiting for a privacy troll to reveal your gaps isn’t a strategy, it’s a vulnerability. But when handled correctly, even these bad-faith actors can highlight opportunities for improvement and reinforce the need for strong, proactive privacy governance.

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Practical Steps to Stay Ahead

Dealing with weaponized DSARs and privacy abuse requires a structured approach, consistency, and readiness. Begin by establishing a clear DSAR policy that outlines how requests are received, evaluated, and documented. 

Ensure that all requests are logged in a centralized system with ongoing audit capabilities. This helps your legal or compliance team track patterns and respond confidently if a regulator comes knocking. Automating parts of the workflow can cut down response time and reduce manual errors. The right privacy infrastructure helps you stay calm under pressure, even when a privacy troll is trying to disrupt things.

Privacy trolls are a growing headache for compliance teams, but they also serve as a reminder that data handling must be taken seriously. With tools like Mine, you can respond quickly, legally, and confidently, whether the request comes from a genuine customer or a privacy troll on a mission.

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