T 2.170 Lack of transparency for the person concerned and authorities in charge of monitoring data protection

If personal data is collected without the person concerned being informed about the planned processing and the legal basis, transparency is disputable.

It is also disputable if the person concerned is not provided with information about the origin and the recipient of this data, as well as deletion periods.

If the authorities in charge of monitoring data protection are not informed timely before

they are hindered from providing suggestions regarding the improvement of data protection in such a timely way that these can still be taken into consideration while the procedure is being developed. The responsibility for complying with the data protection provisions also remains with the data processing centre even if the authorities in charge of monitoring data protection are involved.

The work of the monitoring authorities is made more difficult by a lack of or insufficient logging and documentation when processing personal data and by a lack of updating regarding procedural changes. Efficient control can also be jeopardised by means of incomplete or outdated directories of the IT systems used, inadequate configuration overviews, and missing wiring diagrams.

Missing or incomplete information about the internal directories and, as far as required by law, about the public directories jeopardises the transparency of data processing for the person concerned and the monitoring authorities.

Examples: