quired under the Act and the DPA. Third party information is a complex area and sometimes third party information may also be relevant to the adopted person, for example, in relation to health issues. In addition, the agency should consider whether information is already known or would be available from other sources, e.g. Public Records. 11.43. What is important is that both the Act and the Data Protection Act require the agency to carry out a balancing exercise between the rights of the person requesting disclosure and those of the person to whom the requested information relates to in considering the overall fairness of disclosure. The agency in exercising its discretion will need to take account of the context and all the circumstances of the case. It is important that the reasoning behind any decision as to disclosure is fully recorded. Disclosing protected information about adults (section 61) 11.44. When a person (whether an adopted person or a birth relative or other person with an interest) applies to the AAA for the disclosure of protected information none of which involves a child, the agency has to decide whether to proceed with the application. Before doing so, the agency must take reasonable steps to verify the identity of the applicant (or of any person acting on the applicant’s behalf). This would include meeting the applicant (and their representative) and verifying their identity against the evidence they produce. The agency may request any additional documentation it considers necessary such as a passport, driver’s 217 licence or a certified copy of a birth certificate or adoption certificate. See the practice guidance Adoption: Access to Information and Intermediary Services. 11.45. A person who is unable to submit an application, for example, becaus