On 21 September 2012, the Data Protection Commissioner
("DPC") published his second audit report on Facebook
Ireland following on from the initial detailed audit report that
was published in December 2011. In total, the reports stretch to
over 300 pages. So what have we learned?
First Report – December 2011
In December 2011, the DPC published his initial comprehensive
audit report on Facebook. The audit was triggered by specific
complaints raised by the "Europe-v-Facebook" group, the
Norwegian Consumer Council and others. The job fell to the DPC due
to the fact that Facebook's non-US operations are headquartered
in Ireland. Under Section 10(1)(b) of the Data Protection Acts 1988
and 2003 ("DPAs"), the DPC is obliged to investigate all
complaints, unless they are frivolous or vexations, and to seek to
resolve them in the first instance through amicable resolution.