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Croatia: AZOP issues recommendations on election data processing

On March 26, 2024, the Personal Data Protection Agency (AZOP) published recommendations for the processing of personal data as part of parliamentary elections. Notably, the AZOP stated that for the purpose of advertising and sending personalized messages to voters, political parties/independent lists can rely on the consent of voters or legitimate interest. The AZOP also gave an example that if a voter is a supporter or member of a political party and/or its donor, they can expect to receive a personalized message, i.e., the political party has a legitimate interest in sending such messages. However, the AZOP clarified that the controller must conduct a proportionality test when using legitimate interest and cannot use the same as a blanket rule.

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