Article 10 of the General Data Protection Regulation
(GDPR) specifically limits the processing
of personal data relating to criminal convictions and offences or
related security measures. A number of issues arise when trying to
interpret this article and for this reason, the Commissioner for
the Protection of Personal Data of Cyprus issued an
Opinion[1] (the Opinion) on
the 16/01/2020.
What is Criminal Offence Data?
The GDPR provides extra protection for "personal data
relating to criminal convictions and offences or related security
measures". This includes a wide range of information about
criminal activity, allegations, investigations, proceedings and any
personal data about a specific criminal conviction or trial, but
also any other personal data 'relating to' criminal
convictions and offences. This covers any personal data which is
linked to criminal offences, or which is specifically used to learn
something about an individual's criminal record or
