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ARTICLE · 04 APRIL 2025

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"Check Back Regularly" Clauses Under The Scrutiny Of The Belgian Data Protection Authority. Key Findings On Transparency Requirements

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Recently, the Belgian Data Protection Authority (¨GBA¨) issued Decision no. 51/2025 on a case related to a complainant who tried to register their child for a conservatory using an online platform called "Z".

MaltaPrivacy
Petrus Partene
Petrus Partene
Catalin Veliscu
Catalin Veliscu
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Recently, the Belgian Data Protection Authority (¨GBA¨) issued Decision no. 51/2025 on a case related to a complainant who tried to register their child for a conservatory using an online platform called "Z". Users were required to create an account and, of course, accept Z's general terms and conditions. The complainant rejected having to create an account and introduce the personal data of their child within a third-party platform which was unrelated to the conservatory. Consequently, they requested the deletion of the personal data, due to the fact that there was no legal relationship with Z. In turn, Z claimed it was acting on behalf of the conservatory and processed data lawfully. Z was found to be in breach for multiple infringements of the GDPR and corrective measures were applied by the GBA

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