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The 1998 Data Protection Act was not an extension to, but rather a replacement which retains the existing provisions of the data protection system established by the 1984 legislation. The Act was to come into force from 24 October 1998 but was delayed until 1st March 2000.

In addition to data, manual records were to be brought within the terms of the new data protection system, thus allowing subject access rights to access to such records.

Due to the allowances made for existing institutions to be brought into compliance with the new legislation, manual data processing that began before 24 October 1998 was to comply with the new subject access accommodations of the Act until 2001.