Provisions limiting some of the data controller's obligations under Article 11 are open to misinterpretation — in the way they are used as an argument for rejecting data subjects from exercising their rights under the GDPR. This article takes a look at how Article 11 was misinterpreted by the data controller for the Croatian contact-tracing application, Stop COVID-19, which may have resulted in denying users of the app to exercise their rights.
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