Spain:
SDPA Sanctions Search Engine For Personal Data Communications Without Data Subject's Consent
30 November 2016
by
Daniel J. McLoon
,
Mauricio Paez
,
Kevin Lyles
,
Todd McClelland
,
Jeff Rabkin
,
Adam Salter
,
Michiru Takahashi
,
Undine Von Diemar
,
Olivier Haas
,
Jörg Hladjk
,
Richard Johnson
,
Anand Varadarajan
,
Nicole Perry
and
Alexa Sendukas
Jones Day
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On September 14, the Spanish Data Protection Agency
("SDPA") sanctioned a major search engine for violating
data communication regulations because the search engine had not
obtained user consent prior to transmitting information related to
the right to be forgotten to the webmaster. The SDPA held that such
transmission constituted a personal data communication, and
therefore the consent of the data subject concerned was
necessary.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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