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Bulgaria: CPDP investigates political entities in relation to deceased persons data processing

The Commission for Personal Data Protection ('CPDP') announced, on 23 August 2022, that, following media reports related to the upcoming parliamentary elections of 2 October 2022, it had examined the legality of the processing of personal data of deceased individuals by political entities, for the purpose of registration of parties and coalitions in elections. In particular, the CPDP noted that political parties and coalitions are data controllers and as such are required by Article 25(f) of the Protection of Personal Data Act 2002 (last amended in 2019) to process data of deceased persons only if there is a legal basis to do so. In this regard, the CPDP noted that, for the purposes of registration of parties and coalitions, the Electoral Code SG No. 19/5.03.2014 allows the processing of personal data only of voters and highlighted that deceased persons do not have the status of voters.

In light of the above, the CPDP considered that the processing of personal data of deceased persons in such instances affects the public interest in fair and transparent elections and therefore expressed its intention to carry out an investigation into the political entities concerned.

You can read the press release, only available in Bulgarian, here.