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Somewhat unhelpfully, ICO usually ignores the domestic purposes element of Lindqvist, but quotes the decision when looking at international transfers, so it’s probably safe to ignore what they say on this issue and make your own mind up (admittedly, this is my standard advice). 

GDPR recitals state that purely personal online activity and social networking can still be covered by domestic purposes.

-- 
Tim Turner

On 21 December 2016 at 12:59:52, Rowenna Fielding ([log in to unmask]) wrote:

My understanding is that the ICO's view is at odds with the Lindqvist judgement, so if it's the enforcement risk you're concerned about then follow their line and apply "domestic purposes" to all the individual's processing but if it's litigation that worries you, best stick to the Lindqvist approach and consider Internet publishing to be outside "domestic purposes".

That approach won't hold up after GDPR though, as the ICO will have to stay in line with the other SAs for consistency.

Regards

NADPO Digital Officer 
@NADPONews 

On 21 Dec 2016, 12:48 +0000, Andrew Goodfellow-Swaap <[log in to unmask]>, wrote:

Hi Victoria, what caught my eye, from Lindqvist, was this,

"That [domestic purpose] exception must therefore be interpreted as relating only to activities which are carried out in the course of private or family life of individuals, which is clearly not the case with the processing of personal data consisting in publication on the internet so that those data are made accessible to an indefinite number of people."

That would seem to suggest that that Facebook publishing would almost certainly fall outside 'domestic purposes'.

As for this situation, the purpose of the processing is to attempt to make the Council change its position on an issue. Is that a domestic purpose? Yes, it's being done for the citizen's own benefit but it's being done by sharing information with a public body.

Thanks,

Andrew

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