ABSTRACT
In this blog-post I explore and criticize the puzzling notion of ‘indirect personal data’ used by the CJEU in paragraph 49 of its ruling in C-319/22 Gesamtverband Autoteile-Handel eV v Scania. I note that the concept is problematic for the following reasons. First, the term ‘indirect personal data’ does not appear in the text of the GDPR, nor in earlier relevant case law. Second, even if interpreted as meaning ‘indirectly identifiable data’, the CJEU seems to depart from the test set in recital 26 GDPR – as first clarified in Breyer – to determine whether data relate to an indirectly identifiable natural person.
Stephanie, Rossello, C-319/22 Gesamtverband Autoteile-Handel eV v Scania: how to solve the ‘indirect personal data’ riddle? (February 6, 2024).
Leave a Reply