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Lithuania: VDAI launches public consultation on the assessment of requests for provision of personal data

The State Data Protection Inspectorate ('VDAI') launched, on 13 August 2020, a public consultation for its guidelines ('the Guidelines') on the assessment of requests for provision of personal data, aiming to help data controllers and data processors in the assessment of such requests. In particular, the Guidelines address the main considerations for controllers and processors, including the appropriateness of consent to such disclosure, agreements with data subjects, and the protection of the legitimate interests of data controllers and third parties in accordance with Article 6(1)(f) of the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'). In addition, the Guidelines cover the provision of special categories of personal data, noting that choosing an appropriate basis for the lawful processing of such data does not mean in itself that the provision of that personal data is lawful and recommending that data controllers should assess whether the request meets the criteria for provision of personal data. More specifically, the Guidlines outline that these criteria are the provision of sufficient detail about the purpose behind disclosing personal data, the assessment of whether the person requesting such information is entitled to receive it, and whether the provision of personal data is necessary to achieve the purpose. 

Comments can be submitted until 13 September 2020 to [email protected].

You can read the announcement here and download the Guidelines here, both only available in Lithuanian.