# Guidelines on the right to data portability under Regulation 2016/679, WP242 rev.01

- Type: Guidance
- Source: EDPB
- Identifier: guidelines-on-the-right-to-data-portability-under-regulation-2016679-wp242-en
- Date: 2018-05-25
- Original: https://www.edpb.europa.eu/documents/guideline/guidelines-on-the-right-to-data-portability-under-regulation-2016679-wp242_en
- Canonical: https://overview.legal/posts/126336
- Topics: Pseudonymization, Data Portability, Supervisory Authorities, Supervision, Personal Data

## Summary

J.No. 2022-7320-3298 Doc.no. 495942 Caseworker Ditte Hector Dalhoff The Danish Data Protection Agency Carl Jacobsens Vej 35 2500 Valby Denmark T 3319 3200 dt@datatilsynet.dk datatilsynet.dk VAT No. 11883729 [Name and address] Complaint about Organic Basics ApS 1. The Danish Data Protection Agency (hereinafter referred to as the ‘Danish DPA) returns to the case, where you on 20 October 2020 have complained to the Lander Commissioner for Data Protection and Freedom of Information — Free Hanseatic…

## Sections (4)

### ¶1

The Danish Data Protection Agency (hereinafter referred to as the ‘Danish DPA) returns to the case, where you on 20 October 2020 have complained to the Lander Commissioner for Data Protection and Freedom of Information — Free Hanseatic city of Bremen (hereinafter referred to as ‘DSGVO’) about Organic Basics ApS’ (hereinafter referred to as ‘Organic Ba- sics’) processing of the complainants personal data. Pursuant to Article 56 of the Data Protection Regulation, DSGVO has forwarded the complaint to the Danish Data Protection Agency, which has assumed the role of leading supervisory authority in relation to Organic Basics.

### ¶2

Facts of the case It appears from the case that you made an online purchase from the website of Organic Basics. O n 17 October 2020, you – using a pseudonym – submitted a review about the company on the website Trustpilot, to which Organic Basics replied using your first name. You subsequently complained on 20 October 2020 to the DSGVO about Organic Basics’ use of your first name in the reply on Trustpilot. In the complaint, you have further stated that you are dissatisfied with the fact that you could not find a privacy policy on Organic Basics’ website.

### ¶3

The Danish Data Protection Agency’s assessment The Danish Data Protection Agency finds no basis for taking further action. The Danish DPA has emphasised the nature of the information that Organic Basics has pub- lished about you – general, non-sensitive information in the form of your first name, and that it is doubtful – given the remaining information in Organic Basics reply – whether you are iden- tifiable. The Danish DPA has also emphasised that the information has been published in connection with a response to a review made by you about Organic Basics on Trustpilot, and that the published information does not go beyond what was reasonable and necessary for the com- pany to respond to your review. [date] Page 2 of 2 In regards to Organic Basics lack of privacy policy, the Danish DPA notes that the Danish DPA have found that the company now has a privacy policy on the company’s website. The Danish DPA does not have sufficient grounds to conclude that Organic Basics, at the time the complaint was lodged did not have a privacy policy on the company’s website.

### ¶4

The Danish DPA notes that its decisions cannot be appealed to another administrative au- thority cf. Section 30 of the Danish Data Protection Act. However, decisions taken by the Danish Data Protection Agency may be appealed to the courts, cf. Section 63 of the Danish Constitution. The Danish DPA will take no further action. Kind regards Ditte Hector Dalhoff

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