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ARTICLE · 03 JANUARY 2019

Data Subject Access Rights – And The Requirement To Issue A Copy Of The Undergoing Processing

Within the last couple of months, we have noted that Companies increasingly struggle with data subject access requests.

European UnionPrivacy

Within the last couple of months, we have noted that Companies increasingly struggle with data subject access requests.

The Wording of Art. 15 para. 3 GDPR is Ambiguous

As much as Companies understand that they need to confirm whether they process personal data of the individual that issued the request, they oftentimes seem to struggle with the requirement and the meaning of issuing a copy of the underlying processing as stipulated by Art. 15 para. 3 GDPR.

Not only does the wording of Art. 15 GDPR cause ambiguities, the way the wording is construed varies between scholars and the different supervisory authorities.

Provision of a Copy: Do we have to hand out entire Files.....?

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