CJEU - T‑451/20 - Meta Platforms Ireland Ltd, v. European Commission, Federal Republic of Germany: Difference between revisions

Revision as of 09:02, 14 June 2023

CJEU - T‑451/20 Meta Platforms Ireland Ltd, v. European Commission, Federal Republic of Germany

Court:	CJEU
Jurisdiction:	European Union
Relevant Law:	Article 6(1)(c) GDPR 52(1) Charther Article 7 Charter Article 8 ECHR
Decided:	24.05.2023
Parties:	Meta Platforms Ireland Ltd European Commission
Case Number/Name:	T‑451/20 Meta Platforms Ireland Ltd, v. European Commission, Federal Republic of Germany
European Case Law Identifier:	ECLI:EU:T:2023:276
Reference from:
Language:	24 EU Languages
Original Source:	Judgement
Initial Contributor:	n/a

Meta seeked for an annulment of a decision by the European Commission alleging, inter alia, infringements of the right to privacy. The General Court rejected Meta’s claims.

English Summary

Facts

The European Commission made information requests to Meta Platforms Ireland Ltd (Meta) on the implementation of the rules on competition laid down in Articles 101 and 102 TFEU. Following the requests, the Commission adopted a further decision under Article 18(3) of Regulation No 1/2003 on the implementation of the rules on competition. Following the decision, the Commission requested Meta to provide, inter alia, a number of internal documents meeting certain cumulative criteria. In essence, the requested documents were those prepared by or received by certain depositaries.

Under the decision, Meta was to supply the Commission with the information specified in it. Additionally, the Commission sent Meta a letter proposing a separate procedure for the production of sensitive documents which, according to Meta, contained only personal information wholly unconnected with its commercial activities. Those documents would be placed on the file only after having been examined in a virtual data room.

Thereafter, Meta contested the decision by bringing action before the General Court seeking for an annulment of the decision.

Essentially, Meta relied on four pleas in law – of which one was Meta alleging, inter alia, infringements of the right to privacy. Meta claimed that, by requiring the production of numerous irrelevant documents of a private nature, the decision infringes, inter alia, its right to privacy and that of its staff and third parties, as protected by Article 7 of the Charter and Article 8 ECHR. Furthermore, Meta argued, inter alia, that the Commision’s interference is not provided for by law. Meta claimed that if it would be required to provide information which Meta argued to be irrelevant for the purposes of the investigation, it would contravene Article 6(1)(c) GDPR.

The Commission contended that the Court should declare Meta’s head of claim inadmissible and dismiss the action.

Holding

The Court stated, with regard to Meta's claims presented above, it must be examine whether the contested decision complies with Article 7 of the Charter and satisfies the conditions set out in Article 52(1) of the Charter.

The Court addressed whether there is a legal basis for the interference with privacy. Article 52(1) of the Charter requires that the limitation on the right to respect for private life must be provided for by law, which in the present case, the Court found to exist.

As Meta had claimed that if it would be required to provide information which Meta argued to be irrelevant for the purposes of the investigation, it would contravene Article 6(1)(c) GDPR, the Court essentially held that Meta cannot question the fact that the limitation (to the right to privacy) in question would not be provided by law, because, the Commission adopted its decision on the basis of Article 18(3) of Regulation 1/2003.

It followed, that the Court held, in this particular case, that the decision in question constitutes an interference to the right to privacy – provided for by law – within the meaning of Article 52(1) of the Charter, since Regulation 1/2003 gives the Commission the power to adopt decisions requesting such information.

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@@ Line 54: / Line 54: @@
 === Facts ===
-The European Commission made information requests to Meta Platforms Ireland Ltd (Meta) on the implementation of the rules on competition laid down in Articles 101 and 102 TFEU. Following the requests, the Commission adopted a further decision under Article 18(3) of Regulation No 1/2003. Following such decision, the Commission requested Meta to provide, inter alia, a number of internal documents meeting certain cumulative criteria. In essence, the requested documents were those prepared by or for, or received by, certain depositaries (custodians).
+The European Commission made information requests to Meta Platforms Ireland Ltd (Meta) on the implementation of the rules on competition laid down in Articles 101 and 102 TFEU. Following the requests, the Commission adopted a further decision under Article 18(3) of Regulation No 1/2003 on the implementation of the rules on competition. Following the decision, the Commission requested Meta to provide, inter alia, a number of internal documents meeting certain cumulative criteria. In essence, the requested documents were those prepared by or received by certain depositaries.
 Under the decision, Meta was to supply the Commission with the information specified in it. Additionally, the Commission sent Meta a letter proposing a separate procedure for the production of sensitive documents which, according to Meta, contained only personal information wholly unconnected with its commercial activities. Those documents would be placed on the file only after having been examined in a virtual data room.
@@ Line 65: / Line 65: @@
 === Holding ===
-The Court stated, with regard to Meta's claims presented above, that it is necessary to examine whether the contested decision complies with Article 7 of the Charter and satisfies the conditions set out in Article 52(1) of the Charter.
+The Court stated, with regard to Meta's claims presented above, it must be examine whether the contested decision complies with Article 7 of the Charter and satisfies the conditions set out in Article 52(1) of the Charter.
-Article 52(1) of the Charter provides that any limitation on the exercise of the rights and freedoms recognised by the Charter must be provided for by law and respect the essence of those rights and freedoms. Subject to the principle of proportionality, limitations may be made only if they are necessary and genuinely meet objectives of general interest recognised by the European Union or the need to protect the rights and freedoms of others.
 The Court addressed whether there is a legal basis for the interference with privacy. Article 52(1) of the Charter requires that the limitation on the right to respect for private life must be provided for by law, which in the present case, the Court found to exist.
-As Meta had claimed that if it would be required to provide information which Meta argued to be irrelevant for the purposes of the investigation, it would contravene [[Article 6 GDPR#1c|Article 6(1)(c) GDPR]], the Court essentially held that Meta cannot question the fact that the limitation (to the right to privacy) in question would not be provided by law, because, the Commission adopted its decision on the basis of Article 18(3) of Regulation 1/2003. It followed, that the Court held that the decision in question constitutes an interference to the right to privacy – provided for by law – within the meaning of Article 52(1) of the Charter, since Regulation 1/2003 gives the Commission the power to adopt decisions requesting such information.
+As Meta had claimed that if it would be required to provide information which Meta argued to be irrelevant for the purposes of the investigation, it would contravene [[Article 6 GDPR#1c|Article 6(1)(c) GDPR]], the Court essentially held that Meta cannot question the fact that the limitation (to the right to privacy) in question would not be provided by law, because, the Commission adopted its decision on the basis of Article 18(3) of Regulation 1/2003.
-Furthermore, the Court addressed, inter alia, whether objectives of general interest recognised by the EU were pursued and found that the decision adopted by the Commission does meet the objectives of general interest recognised by the EU. The decision was found to express the exercise of the Commission’s powers under the regulation, which contributes to maintaining competition intended by the EU treaties, which the Court viewed businesses to have an absolute duty to comply with.
+It followed, that the Court held, in this particular case, that the decision in question constitutes an interference to the right to privacy – provided for by law – within the meaning of Article 52(1) of the Charter, since Regulation 1/2003 gives the Commission the power to adopt decisions requesting such information.
 == Comment ==