Dutch DPA Objects to Human Trafficking Directive Decree Over Unregulated Processing Bases
The Dutch Data Protection Authority (AP) has formally objected to the draft decree implementing the revised EU Human Trafficking Directive. It found that the GDPR legal bases of public interest task and legal obligation are not properly established in law. Without further regulation, processing of victims' personal data, including special category and criminal data, could be unlawful. Compliance teams should treat this as a signal of how strictly regulators apply the Article 6(3) requirement.


