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Hungary: NAIH issues guidance on obligations of individuals providing accommodation services

The National Authority for Data Protection and Freedom of Information (NAIH) issued on May 31, 2023, guidance on the obligations of individuals providing accommodation services as data controllers. The NAIH explained that since such processing is carried out for business purposes, the General Data Protection Regulation (GDPR) applies. Consequently, the NAIH highlighted that some of the data processing will need to comply with the provisions of Articles 5 and 6(1) of the GDPR. In addition, the NAIH noted transparency obligations under Articles 13 and 14 of the GDPR, as well as rights and remedies available to data subjects as set out in Articles 15-23, 77, and 79-80 of the GDPR.

Importantly, the NAIH detailed that given that data management related to accommodation services typically does not involve a high risk for the rights and freedoms of the persons concerned, accommodation providers typically do not need to prepare a Data Protection Impact Assessment (DPIA), also confirming that a private individual providing accommodation services does not need to appoint a data protection officer (DPO). Furthermore, the NAIH highlighted that there are also additional requirements to be considered in the Act on State Duties Pertaining to the Development of Tourism Regions, including registration obligations and record keeping.

The NAIH emphasized that its legal interpretation based on the information provided in the submissions does not bind other authorities, the court, or the data controller, and is only indicative.

You can download the notice, only available in Hungarian, here.