IP - 0611-762/2020/8

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IP - 0611-762/2020/8
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Authority: IP (Slovenia)
Jurisdiction: Slovenia
Relevant Law: Article 6 GDPR
Type: Investigation
Outcome: No Violation Found
Started:
Decided: 10.02.2021
Published: 15.03.2021
Fine: None
Parties: n/a
National Case Number/Name: 0611-762/2020/8
European Case Law Identifier: n/a
Appeal: n/a
Original Language(s): Slovenian
Original Source: GDPR planet (via IP’s ZIP files) (in SL)
Initial Contributor: GDPR plus

The Slovenian DPA decided that car registration plates may be personal data.

English Summary

Facts

The IP was told that the controller, as manager, had conditioned the regulation of the access of vehicles of the apartment owners to the owners' garage of an apartment building at the address ... XY conditioned the access by obtaining information about their license plates. Thus, by recognizing the license plate numbers that the controller would maintain in the system, the camera would recognize the license plate number and provide access to the garage.

Dispute

Holding

An essential condition for the vehicle data (including the registration number) to become personal data is therefore that it is possible to identify the person precisely through them. In the specific case, other personal data (addresses, apartment numbers) are processed in addition to the registration plates, so that the individual is identified or can be identified. IP considers that the registration plates of vehicles should be treated as personal data due to their nature, their purpose and the possible identifiability of the individual.

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English Machine Translation of the Decision

The decision below is a machine translation of the Slovenian original. Please refer to the Slovenian original for more details.