Editing IP - 07121-1/2020/2281

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The Slovenian DPA (IP) issued an advisory opinion about the use of personal data for advertising purposes on Facebook and joint controllership. It underlined that each controller needs a legal basis for processing personal data.
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The Slovenian DPA issued an advisory opinion about the use of personal data for advertising purposes on Facebook and joint controllership, underlining that each controller needs a legal basis for processing personal data.
  
==English Summary==
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== English Summary ==
  
===Facts===
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=== Facts ===
 
The Slovenian DPA received a complaint regarding the use of the complainant personal data for advertising purposes inside of a Facebook group. The DPA advised that the group administrator should first provide an appropriate legal basis for transferring the personal data to Facebook for advertising purposes and, second, for transferring personal data to the users of the SNS (Social Networking Service). In such a case, the group administrator will, together with Facebook, act as joint controller for the processing of personal data related to the ads.
 
The Slovenian DPA received a complaint regarding the use of the complainant personal data for advertising purposes inside of a Facebook group. The DPA advised that the group administrator should first provide an appropriate legal basis for transferring the personal data to Facebook for advertising purposes and, second, for transferring personal data to the users of the SNS (Social Networking Service). In such a case, the group administrator will, together with Facebook, act as joint controller for the processing of personal data related to the ads.
  
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Finally, the DPA reasoned that the ad in question, shown only in the Facebook group, was likely only meant for the group members and not for the general public. Publishing the ad inside of a Facebook group, although publicly, doesn't mean it will be read by all Facebook users, but likely only by the group members that are only interested in the content relevant for the group.
 
Finally, the DPA reasoned that the ad in question, shown only in the Facebook group, was likely only meant for the group members and not for the general public. Publishing the ad inside of a Facebook group, although publicly, doesn't mean it will be read by all Facebook users, but likely only by the group members that are only interested in the content relevant for the group.
  
===Dispute===
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=== Dispute ===
  
  
===Holding===
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=== Holding ===
 
The Slovenian DPA advised that each controller of personal data must have a legal basis for such processing.
 
The Slovenian DPA advised that each controller of personal data must have a legal basis for such processing.
  
==Comment==
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== Comment ==
 
Interestingly, Slovenia still has not implemented fully the GDPR. They are still relying on ZVOP-1, as ZVOP-2 (national data protection act) still has not been introduced. The DPA issues only non-binding opinions.
 
Interestingly, Slovenia still has not implemented fully the GDPR. They are still relying on ZVOP-1, as ZVOP-2 (national data protection act) still has not been introduced. The DPA issues only non-binding opinions.
  
==Further Resources==
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== Further Resources ==
 
''Share blogs or news articles here!''
 
''Share blogs or news articles here!''
  
==English Machine Translation of the Decision==
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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.
 
The decision below is a machine translation of the Slovenian original. Please refer to the Slovenian original for more details.
  

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