The right of access to information about specific recipients of personal data: commentary on the ruling of the Court of Justice of the European Union in case C-154/21

Abstract

The commented ruling interprets the right of access of interested parties to know the specific recipients of their data in the event that it has been communicated to third parties. It is necessary to distinguish the obligation to inform about data processing by the person responsible from the right of access by the interested party. Only this right of access to specific recipients allows the exercise of other data protection rights. The Court of Justice, however, appreciates two limitations to this right: on the one hand, that it is materially impossible to satisfy it and on the other, that the exercise of the right is not manifestly unfounded or excessive, extremes that must be proven by the data controller.