The Irish Data Protection Commission announced its final decision following an inquiry into LinkedIn Ireland Unlimited Company. This inquiry was launched by the DPC, in its role as the lead supervisory authority for LinkedIn, following a complaint initially made to the French Data Protection Authority. The inquiry examined LinkedIn’s processing of personal data for the purposes of behavioral analysis and targeted advertising of users who have created LinkedIn profiles. The decision, which was made by the Commissioners for Data Protection, Dr Des Hogan and Dale Sunderland, and notified to LinkedIn on October 22, concerns the lawfulness, fairness and transparency of this processing. The decision includes a reprimand, an order for LinkedIn to bring its processing into compliance, and administrative fines totaling EUR 310M. DPC Deputy Commissioner Graham Doyle commented: “The lawfulness of processing is a fundamental aspect of data protection law and the processing of personal data without an appropriate legal basis is a clear and serious violation of a data subjects’ fundamental right to data protection.”
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