For example, the obligation to record visitor and customer data will be dropped in the areas of gastronomy and cultural events. As far as known so far, however, the obligation to collect contact data will continue to apply to large events with more than 1000 people. In addition, the obligation will remain in clubs, discotheques and comparable leisure facilities. Likewise, the now customary contact data collection will remain in place for gastronomic offerings with dance music, for services close to the body, and in community accommodations.
Wherever the obligation to collect contact data ceases to apply, the previous legal basis on which this data processing was based also ceases to apply. This means that data controllers who previously collected contact data must check whether they are still obliged and authorized to do so. If the legal obligation to do so ceases to apply, the authorization may also cease to apply and the corresponding data processing would be unlawful in cases where there is no other legal basis.
We are happy to help our customers and anyone who wants to become our customer to check whether a contact data collection is still permitted under data protection law. Just give us a call or make an appointment with us.