Surely a record of personal data in date order is “structured according to specific criteria” so does not get excluded by Recital 15?
Donald
I don't think it's structured by reference to individuals but it might be said it's structured by reference to criteria relating to individuals.
I think I could muster an argument either way, but on balance though I don't think a date is a criterion relating to individuals, bearing in mind that the directive says that the structure should be "so as to permit easy access to the personal
data in question".
Surely, it is a filing system - it is clearly organised by date...
Donald
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Phil Bradshaw
Sent: 14 October 2017 14:59
To: [log in to unmask]
Subject: Re: [data-protection] GDPR and visitor books
Depends of course on what you mean by a visitors book. However if you mean the traditional paper book in a guest house, hotel or tourist attraction I would simply not regard it as a filing system and so it is outside scope of GDPR - Article 2(1) just as is
currently outside DPA.
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