GDPR: Are You Sufficiently Transparent In Your Data Processing?

Two years after the EU's General Data Protection Regulation (GDPR) entered into force, Europe as of 25 May 2018 is faced with a new legal situation. It remains to be seen which obligations will be at the focus of the supervisory authorities and data subjects. Nevertheless, the provisions on transparency in the processing of personal data are expected to be a priority concern.

The GDPR specifies several principles that need to be complied with when processing personal data: lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality and the obligation to provide evidence for compliance with these principles. Whether some of these are considered of a higher order than others cannot be deduced from the Regulation.