QuestionQ277

European Data Protection: Scope and Accountability

Which of the following is not necessarily a factor in determining whether the processing could be regarded as “cross-border processing”?

  • A The total number of data subjects.
  • B The potential harm for the data subjects.
  • C The collection of personal data of children.
  • D The processing of a wide range of personal data
Explanation

The number of data subjects affected, even if large and spread across multiple Member States, does not on its own establish that processing substantially affects individuals. Relevant case-by-case considerations include potential damage or distress, intrusive processing involving children’s data, and processing a wide range of personal data.

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