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ARTICLE · 04 JANUARY 2019

Corporate Holiday Cards: The GDPR Nightmare Before Christmas?

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The year 2018 is coming to a close. Among other things, it has brought us a new FIFA world champion, royal weddings and some other joyful things like the EU General Data Protection Regulation (GDPR).

GermanyPrivacy
Benjamin Beck
Benjamin Beck
Ana Elisa Hadnes Bruder
Ana Elisa Hadnes Bruder
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The year 2018 is coming to a close. Among other things, it has brought us a new FIFA world champion, royal weddings and some other joyful things like the EU General Data Protection Regulation (GDPR). The latter could arguably cool one's Holiday spirit—at least in some cases. For example, reportedly, the annual wish list campaign of the City of Roth, Germany, was intitally cancelled due to GDPR concerns. However, the GDPR could also affect other festive matters like sending corporate Holiday cards.

Addresses are Personal Data

Street and email addresses are considered personal data according to Art. 4, No. 1 of the GDPR, because, either by themselves or in combination with other data, they can be used to identify an individual person. Thus, if someone uses an address to, e.g., get into contact, he or she is processing personal data within the meaning of Art. 4 No. 2 of the GDPR, which is only lawful if a legal basis under Art. 6 GDPR applies.

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