QQuestions:
The law requires to undertake personal data "combination" with authorization. What is data combination? If existing personal data are already in combination, does it constitute a breach of law?
AReply

Data combination refers to the fact that data in one database are linked to that in another, or data connections are built between one or several databases of an institution, or correlations between data are established between databases of different purposes of a same institution. Except where data combination is provided for in laws or statutory regulations, all data combination must be performed with the authorization of the PDPB, which may be sought via application by the entity or co-entities responsible for processing the data in question. Where data were already in combination before the Personal Data Protection Act came into effect, the database operator entity should apply to the PDPB as soon as possible for approval.

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