Ten Examples Of Data Processing Activities That Don’t Require A DPIA According To France’s CNIL

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Fox Rothschild LLPThe French Data Protection Authority CNIL has issued guidance on types of data processing for which a Data Protection Impact Assessment (DPIA) is not required under GDPR:

  • HR-related processing, not including profiling, for companies with under 250 employees (e.g: payroll , training, employee timekeeping – without biometrics, evaluations)
  • Processing solely for calculating working time (except with biometrics or sensitive personal data)
  • Relationship with suppliers (vendors) e.g. contract admin, payment
  • Electoral registers – Activities of works council (EU unions)
  • Processing non-sensitive information by an association, foundation or nonprofit (e.g. management of members and donors, member directories, communication for prospecting)
  • Processing data related to patient health by a medical professional within a doctor’s office, pharmacy or medical lab (e.g. appointments, medical records, communication among the medical professionals involved)
  • Processing by lawyers for client management
  • Processing by clerks and notaries
  • Processing by local authorities and private companies for managing school and daycare /after-school programs (e.g. registration, billing, catering, transportation, school trips)
  • Processing relating to alcohol detection breathalyzers

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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