R318. Notify third parties of changes

Requirement

The system must notify third parties when it rectifies or erases shared personal information.

Description

Systems usually request information from their users, obtain it from third parties or collect it based on their interactions with the application. They sometimes share personal information with third parties after having requested consent from its owner. Whenever this information is rectified or erased upon request from its owner, the system must notify said third parties so that they do the same. This is also the case when the user requests that the system stop processing their data.

Exceptions

  1. The system must proceed with the notification unless it is impossible or involves disproportionate effort.

  2. The processing of the personal information might have archiving purposes in the public interest. If the system properly safeguards this information and if complying with this requirement seriously impairs these purposes, this requirement is not applicable.

References

  1. GDPR. Art. 19: Notification obligation regarding rectification or erasure of personal data or restriction of processing. The controller shall communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

  2. GDPR. Art. 89: Safeguards and derogations relating to processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.(3). Where personal data are processed for archiving purposes in the public interest, Union or Member State law may provide for derogations from the rights referred to in Articles 15, 16, 18, 19, 20 and 21.

  3. ISO 27001:2013. Annex A - 18.1.4 When applicable, guarantee the privacy and security of personal information, as required by the relevant legislation and regulations.

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