Poland: UODO dismisses administrative proceedings regarding publication of membership by judges and prosecutors
The Polish data protection authority ('UODO') issued, on 15 April 2020, a decision ('the Decision') dismissing the administrative proceedings that had initiated on the publication of membership in an association for judges and prosecutors. In particular, the Decision highlights that the publication of membership is required by law, and therefore the processing of personal data of judges and prosecutors to satisfy the legal obligations under the law, based on Article 6(1)(c) of the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'). Therefore, the Decision notes that the UODO had no grounds to establish a violation of the provisions on the protection of personal data.
UPDATE (21 April 2020)
UODO issues statement on the submission of declarations by judges
The UODO issued, on 20 April 2020, a statement ('the Statement') explaining that the submission of declarations by the judges of membership in associations, does not violate the GDPR, as Article 6(1)(c) of the GDPR allows the processing of personal data to fulfil a legal obligation. In particular, the Statement notes that the UODO presented this position in its letter ('the UODO Letter') to the President of the Supreme Administrative Court letter ('the Court Letter') who argued that this processing may violate the GDPR provisions.