LINDQUIST, 6.11.2003 (“LINDQUIST”)

Definition of processing: The operation of loading personal data on an internet page must be considered to be processing. (¶ 25)

According to the definition in Article 2(b) of Directive 95/46, the term ‘processing’ of such data used in Article 3(1) covers ‘any operation or set of operations which is performed upon personal data, whether or not by automatic means’. That provision gives several examples of such operations, including disclosure by transmission, dissemination or otherwise making data available. It follows that the operation of loading personal data on an internet page must be considered to be such processing.