Publication of old club magazines Summary Our remarks A citizen complained to the Danish DPA that Jyllinge • The decision provides an example of how the Sejlklub, a sailing association, had published three of balancing of interests under GDPR, Article 6(1)(f) its club magazines from 1981 and 1982 on the internet, can favour the data controller. The Danish DPA which contained information about the complainant’s emphasized, among other things, that in this case: name, address, age, and picture, and that the 1. the data controller had a legitimate interest in association refused the complainant’s request for safeguarding, protecting, and informing about erasure of the information. its history in a natural context, The Danish Data Protection Agency’s 2. the club magazines had been available for decision almost 40 years, and The Danish DPA did not express criticism, as Jyllinge 3. the types of personal data in the magazines Sejlklub’s processing of personal data was carried out were of a very non-invasive nature. in accordance with the rules in GDPR, Articles 6(1) and • The decision serves as an example of when the 17. data subject may not exercise their right to erasure. In the opinion of the Danish DPA, the prerequisites for erasure, as outlined in GDPR, Article 17(1)(a-f), were not met. The DPA emphasized, among other things, that the data controller still needed to process the complainant’s information and that the data controller processed the complainant’s data on a lawful basis. The authority also emphasized that the complainant did not provide specific grounds that would override the controller’s legitimate interests in processing the complainant’s data under GDPR, Article 17(1)(c), and Article 21(1). Published: 08-06-2020, Journal number: 2019-31-2363 Tags: 01 Legal basis for processing and principles for processing 101