Читать книгу Privacy and Data Protection based on the GDPR - Leo Besemer - Страница 44

“filing system” means any structured set of personal data which are accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis.

GDPR Article 4(6)

Note that a filing system is not necessarily digital. A set of paper folders ordered in some way and containing information about people is also considered a filing system.

So, if the butcher shop had used an information system, even if it were non-automated (like an alphabetically ordered set of index cards), then the butcher would need a legitimate purpose to process this information. In Part II we will see that the butcher indeed has a legitimate ground for processing personal data (preparation of an agreement to sell meat products), so even then asking for consent would not have been necessary. In the given case there is no filing system, the butcher just remembers the name and preferences, no technology is involved. Consequently, this processing is outside the scope of the GDPR.