Linkedin Ireland Unlimited Company – Court Ruling (Ireland, 2026)

The case arose from LinkedIn’s appeal against a decision of the Irish Data Protection Commission, the DPA, dated 22 October 2024. In that decision, the DPA found that LinkedIn had infringed GDPR Articles 5(1)(a), 6(1), 13(1)(c) and 14(1)(c). The DPA imposed a reprimand, an order requiring LinkedIn to bring processing into compliance, and three administrative fines totalling €310 million. The underlying DPA inquiry followed a complaint lodged by La Quadrature du Net with the French supervisory authority, CNIL, on behalf of 8,540 LinkedIn users in France. The complaint concerned LinkedIn’s processing of personal data for behavioural analysis and targeted advertising. CNIL referred the matter to the DPA because LinkedIn Ireland was subject to the Irish supervisory authority in the context of cross-border processing. The DPA investigation lasted more than six years. The DPA first notified LinkedIn of the inquiry on 20 August 2018. After several requests for information, submissions, a preliminary draft decision, a draft decision under Article 60 GDPR and comments from concerned supervisory authorities, the DPA adopted its final decision on 22 October 2024. LinkedIn then brought a statutory appeal under [https://www.irishstatutebook.ie/eli/2018/act/7/enacted/en/print sections 142 and 150 of the Data Protection Act 2018]. It also issued judicial review proceedings challenging aspects of the statutory scheme under the Constitution, the Charter and the ECHR. The High Court judgment did not decide the merits of the DPA’s GDPR findings. Instead, it dealt with four preliminary issues about the structure and standard of appeal. The key dispute was whether LinkedIn could challenge the entire DPA decision under section 142, because that decision included a fine, or whether section 142 was limited to the fine only. LinkedIn argued for a broader, unitary appeal. The DPA and the State argued that section 142 applied only to the administrative fine, while infringement findings and no