- Enforcing jurisdiction
- Iceland · Geography does not establish applicable law.
- Confirmed applicable legislation
- No confirmed legal basis recorded.
- Privacy topics
Complainant – Dismissed (Iceland, 2022)
Privacy enforcement record
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Iceland's data protection authority dismissed a complaint against Gallup for looking up phone numbers to invite people to surveys. The authority found that Gallup's actions were necessary for their research and did not violate privacy rights. This case shows that companies can process personal data for legitimate interests if they balance those interests with individuals' rights.
What happened
The complaint against Gallup for processing phone numbers without consent was dismissed.
Who was affected
Individuals whose phone numbers were looked up by Gallup for survey participation.
What the authority found
The authority agreed that Gallup's processing was necessary for their legitimate interests in conducting research.
Why this matters
This case illustrates that companies can use personal data for research purposes if they justify their legitimate interests. Businesses should ensure they have a valid reason for processing personal data.
Entities Involved
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The dispute concerns an issue where the research company Gallup (the controller) looks up data subjects' phone numbers on the online database www.ja.is and stores these in their internal database, to be able to call the data subjects and invite them to participate in surveys. A data subject lodged a complaint against this processing of their personal data, arguing that they never agreed to the processing, nor did the controller inform them about the processing and purposes for the processing. The controller claimed that the processing of personal data in question was necessary because of their legitimate interests in ensuring sufficient research quality and participation rate, including allowing for all adult citizens to have an equal opportunity to respond to national registry surveys. Even without a database, the controller would have to research and call participants. Further, the controller stored personal data in a do-not-call list to avoid contacting data subjects again who had previously objected to this. The controller concluded that the disadvantages for the processing activities were minimal for the data subjects. The Icelandic DPA rejected the complaint. The DPA noted that pursuant to Article 6 GDPR, personal data may be processed if it is necessary for the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data are outweighed. Based on this provision, the DPA agreed with the controller that if they had to look up the phone numbers of every single person in the national register sample for every survey, it would entail a lot of time-consuming work and could have a negative effect on the quality of research. In addition, Gallup uses the phone number database to keep track of those individuals who have declared to the company's staff that they no longer wish to be invited to participate in the company's research. The DPA therefore he
Outcome
Dismissed
The complaint or investigation was dismissed.
Related Enforcement Actions (0)
No other enforcement actions found for Complainant in IS
This is the only recorded action for this entity in this jurisdiction.
Details
Decision Date
23 November 2022
Authority
Persónuvernd
About this data
Cite as: Cookie Fines. Complainant - Iceland (2022). Retrieved from cookiefines.eu
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