What must be provided to data subjects when the personal data will be processed and was collected indirectly?

When personal data is collected indirectly and will be processed, it is essential to provide the data subjects with the source of that data. This requirement aligns with transparency obligations under the General Data Protection Regulation (GDPR), which emphasizes the need for individuals to be informed about the origins of their personal data.

In cases where data is not collected directly from the individuals, informing them about the source ensures they understand where their data is coming from, which is crucial for them to assess its accuracy and legitimacy. This knowledge empowers data subjects as they navigate their rights and helps build trust between them and the data controller.

While the storage period, statutory or contractual requirements, and the controller’s legitimate interest are also important components of transparency, they do not specifically address the indirect collection of personal data as effectively as informing individuals about the source does. Thus, highlighting the source of the data effectively meets the specific need for clarity regarding how and from whom the data was obtained.