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Third Party Response

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Guest user Created:   Dec 15, 2022 Last commented:   Dec 15, 2022

Third Party Response

Would appreciate your insight with regards to an entity that identifies people based upon a profile in LinkedIn. 

What are the Privacy implications regarding accessing PII through third Party Platform.

How would one go about confirming Data Subjects “Consent” pertaining to third party processing and archiving Data 

Look forward to your valued response.

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EU GDPR DOCUMENTATION TOOLKIT

Step-by-step implementation for smaller companies.

EU GDPR DOCUMENTATION TOOLKIT

Step-by-step implementation for smaller companies.

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Tudor Galos Dec 15, 2022

When you are accessing data of a data subject on LinkedIn, you are processing that individual’s personal data, and according to article 6 – Lawfulness of processing – you need at least one legal ground for processing: consent, contractual obligation, legal obligation, vital interest, public interest, legitimate interest. If that person is contacted using LinkedIn platform’s features, such as Add Connection, InMail, Messaging, you don’t need data subject’s consent for processing, as that person already accepted LinkedIn’s Terms and Conditions, which allow that person to be contacted (if he/she didn’t modify the privacy preferences in the account). However, if you download/archive a person’s data from LinkedIn, you need another legal ground for the processing. It can be consent, but you need to obtain that person’s consent BEFORE you download/archive his/her data from LinkedIn.

Please also consult these resources:

Tudor Galos
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Dec 15, 2022

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