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ARTICLE · 10 JANUARY 2019

The Israeli Privacy Protection Authority Required To Register Email Addresses Databases

We would be happy to provide further advice and recommendations concerning the new regulatory Opinion and its practical implications.

IsraelPrivacy

The Israeli Privacy Protection Authority has published today (28/11) an opinion regarding the question of whether the data protection requirements set out under the Israeli Privacy Protection Law apply to a digital database that contains individuals' names and email addresses ("the Opinion").

The Privacy Protection Authority has clarified that a database that contains individuals' names and email addresses would be regarded as "personal information" per the Law.

More importantly, while Article 7(2) of the Law excludes "collection that includes only the name, address and method of communication" from the definition of a "database" under the Law (subject to fulfillment of certain conditions), it was clarified that a database containing individuals' names and email addresses would not fall within this exclusion, given that email addresses may, in some instances, reveal additional information relating to the individuals (such as private matters or a persons' beliefs).

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