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Lithuania: VDAI issues recommendation on processing of debtors' personal data

January 11, 2022
Summary

On 5 January 2022, the State Data Protection Inspectorate (VDAI) of Lithuania issued a recommendation regarding the processing of debtors' personal data under the GDPR. The recommendation clarifies data protection principles, lawful processing grounds, and the roles and responsibilities of involved parties. It also states that exercising GDPR rights does not equate to a debt review and does not impact contractual obligations between debtors and creditors. Furthermore, the VDAI clarified it does not have authority over debt calculation methods or the determination of debt validity.

The State Data Protection Inspectorate ('VDAI') announced, on 5 January 2022, that it had issued a recommendation on the processing of debtors' personal data. In particular, the VDAI outlined that the recommendation aims to facilitate an understanding of the rules applicable to the processing of debtors' personal data under the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR') and discusses key data protection considerations such as data processing principles, lawful grounds for processing, and the roles and duties of relevant parties. Notably, the VDAI highlighted that that the exercise of the data subject's rights enshrined in the GDPR does not imply a debt review, fur

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