President of Personal Data Protection Office has initiated an administrative proceeding concerning an alleged violation of GDPR by the Chief Surveyor by processing of personal data in the form of numbers of land register on the GEOPORTAL2 website without legal basis.
The Chief Surveyor, on the basis of agreements concluded with local government officers from several districts, enabled GEOPORTAL2 to obtain land register numbers of land properties. President of Personal Data Protection Office considered this action to be illegal and indicated that the land register numbers are personal data and that the Chief Surveyor had no legal basis for their processing. In the decision from 24th of August he prohibited the publication of the upper mentioned data.
Stance of the President of Personal Data Protection Office raises concerns. Land register numbers are not data about a person, but about things. The land register as a public register contains personal data, however such data is also included in different registers such as National Court Register, which is publicly accessible to everyone.