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by threatofrain 2945 days ago
If a European butcher takes notes on his customers using a paper notebook or Excel, are these different modes of data-management subject to GDPR?

How are you about to answer that with US IP law?

2 comments

Article 2:

> This Regulation applies to the processing of personal data wholly or partly by automated means and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of a filing system.

Which makes sense, just keeping customer data on paper instead of in digital storage shouldn't mean you don't have to protect it.

Ah, it says automated. I wonder if that mean manual human input changes things, even manual human input in Excel.
Don't think it does. Basically everything involving a computer probably qualifies as "automated", and an Excel document is probably structured enough to be a "filing system".
What kind of notes? I am not an expert in GDPR law since I don't track people, hopefully someone here would explain exactly what is PI and what is tracking and if will apply in this exact case.