Processing Personal Data
According to Art. 3 letter e DPA, processing of personal data is any operation with personal data, irrespective of the means applied and the procedure. In particular, the collection, storage, use, revision, disclosure, archiving or destruction of data is considered processing of personal data. Any processing of personal data has to be made in compliance with the substantive requirements. Additionally, certain formal requirements may apply to data processing under certain circumstances, such as information duties, registration duties and granting data subjects’ rights to access personal data, and, as the case may be, to request correction or deletion of their personal data. Unlawful processing may lead to sanctions and data subjects have specific remedies in case of an infringement of their personality rights due to an unlawful data processing.