Retention of personal data provided online [2008] IEDPC 13
X. retained personal data, including credit card details, for longer than necessary and failed to provide an Irish-specific privacy policy. The Data Protection Commission found that a twelve-month retention period was more appropriate and required X. to update its privacy policy and opt-in mechanisms for data retention.
- Citation
- [2008] IEDPC 13
- Parties
- Complainant: Complainant (Data Subject); Respondent: X.
- Jurisdiction
- Ireland
- Procedural Posture
- Data Protection Complaint / Decision After Investigation
- Outcome
- Complaint upheld with recommendations implemented
- Legal Topics
- Retention of Personal Data, Privacy Policy Compliance, Data Subject Rights, Credit Card Data Retention
Case Brief
Summary, issues, holding and outcome
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Parties
Complainant (Data Subject)
Complainant
X.
Respondent
Procedural Posture
Data Protection Complaint / Decision After Investigation
Legal Issues
- 1 Whether X. retained personal data longer than necessary
- 2 Whether X.'s privacy policy complied with Irish law
- 3 Whether X. provided adequate opt-out mechanisms for communications
Ratio Decidendi
X. retained personal data, including credit card details, for longer than necessary and failed to provide an Irish-specific privacy policy. The Data Protection Commission found that a twelve-month retention period was more appropriate and required X. to update its privacy policy and opt-in mechanisms for data retention.
Court Disposition
Complaint upheld with recommendations implemented
Orders
- X. to delete personal data after twelve months of inactivity
- X. to update privacy policy to reflect Irish law
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