Archbishop of Dublin – Order (Ireland, 2023)
General GDPR enforcement action
This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.
The Irish Data Protection Commission decided that the Archbishop of Dublin can keep personal data in church baptism registers, even if people ask for it to be erased. The decision is important because it clarifies that religious organizations can have legitimate reasons to retain certain personal data.
What happened
The Archbishop of Dublin was allowed to retain personal data in baptism registers despite requests for erasure.
Who was affected
Individuals who had their personal data recorded in church baptism registers and wanted it erased.
What the authority found
The Data Protection Commission found that the Archbishop could rely on legitimate interests to keep the data, which outweighed individuals' requests for erasure under GDPR.
Why this matters
This case highlights that organizations, including religious ones, can have legitimate reasons to keep personal data, even if individuals want it erased. It underscores the need for organizations to balance their interests with individuals' rights under GDPR.
GDPR Articles Cited
The DPC commenced the Inquiry following receipt of a number of complaints from individuals who wished to obtain erasure in relation to their personal data processed in church registers. All of the individuals had written to either their parish or to the Archdiocese asking for the erasure of their data pursuant to Article 17 GDPR. • The Archbishop may lawfully rely on legitimate interests under Article 6(1)(f) GDPR as a legal basis for the processing of personal data of individuals which are recorded in the Baptism Register, even in such instances where an individual no longer wishes to be associated with the Catholic Church; • Subject to safeguards, the Archbishop’s interests in retaining the personal data contained in the Baptism Registers are not overridden by the interests or fundamental rights and freedoms of the individuals; • The Archbishop may rely on the legal basis under Article 9(2)(d) of the GDPR for the processing of individuals’ special category data during the course of their lifetime; The Archbishop, in processing the special category personal data in the Baptism Registers, has in place appropriate safeguards for such processing as required under Article 9(2)(d) GDPR; • Individuals may exercise the right to request rectification of the personal data contained in the Baptism Registers, in accordance with Article 16 GDPR; • The Archbishop must comply with his obligations under Article 12(3) and Article 12(4) of the GDPR in order to facilitate requests in relation to individual’s rights under Articles 15 to 22 of the GDPR; • Individuals who no longer consider themselves to be members of the Catholic Church do not have the right to obtain erasure of their personal data in the Baptism Registers under the grounds set out at Article 17(1)(a)-(f) of the GDPR; • In circumstances where an individual no longer wishes to be a member of the Catholic Church, a supplementary statement could be added by the Archbishop to the Baptism Register entry stating “No longe
Outcome
Order
A binding order requiring the controller to take specific action.
Related Enforcement Actions (0)
No other enforcement actions found for Archbishop of Dublin in IE
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. Archbishop of Dublin - Ireland (2023). Retrieved from cookiefines.eu
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