Q&As

Does the GDPR apply to an online forum, if the members use nicknames or pseudonyms?

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Published on LexisPSL on 04/06/2018

The following Risk & Compliance Q&A provides comprehensive and up to date legal information covering:

  • Does the GDPR apply to an online forum, if the members use nicknames or pseudonyms?
  • Territorial scope
  • The definition of personal data

There are two issues to consider:

  1. territorial scope

  2. the definition of personal data

Territorial scope

See Practice Note: The General Data Protection Regulation (Territorial scope) which explains that the GDPR applies to the processing of personal data by organisations:

  1. operating within the EU, regardless of whether the processing takes place in the EU (the establishment test); or

  2. outside the EU that

    1. offer goods or services to individuals in the EU, irrespective of whether payment is required (the goods and services test); or

    2. monitor the behaviour of individuals in the EU (the monitoring test)

The estab

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