The Court of Justice of the European Union (CJEU) has ruled in Case C‑740/22 that the concept of processing personal data under the EU General Data Protection Regulation (GDPR) should be interpreted broadly and includes oral disclosure. Specifically, Article 4(2) of the GDPR contains no restrictions preventing oral disclosures as "processing". Furthermore, such an interpretation aligns with the EUs objective of ensuring a high level of protection for personal data.
The CJEU also examined the relationship between the GDPR and the right of public access to official documents. After considering the sensitivity of data related to criminal convictions and the impact of such disclosures, the CJEU ruled that the GDPR does not permit disclosure of such information to any person who requests it without requiring the requester to establish a specific interest.
Additional legal analysis by 11KBW Panopticon Blog.
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