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Liechtenstein: DSS publishes newsletter issuing guidance on GDPR compliance
On April 23, 2024, the Liechtenstein Data Protection Authority (DSS) published a newsletter addressing compliance under the General Data Protection Regulation (GDPR), age restrictions for social media accounts, and video surveillance in public spaces.
Compliance with Article 15 of the GDPR
The DSS highlighted that in compliance with Article 15 of the GDPR entities must not only provide data subjects with access to their personal data but they must also provide details on the purposes of processing, categories of data processed, recipients of data, storage duration, data subject rights, and sources of the data.
Age restrictions for social media accounts
Notably, the DSS pointed out that while individuals aged 14 and above may enter certain contracts independently as per Article 18 of the Persons and Companies Act (PGR), they must be at least 16 years old to independently create social media accounts or consent to data processing. The DSS explained that for children under 16, the consent of a legal guardian is required, in line with Article 8 of the GDPR.
Video surveillance in leisure facilities
The newsletter also reported on a judgment by the Liechtenstein Administrative Court (VGH), which upheld the DSS's position that privacy interests generally outweigh the benefits of surveillance in leisure settings. According to the DSS, video surveillance is permissible only under exceptional circumstances and this strict approach applies equally to restaurants, hotels, employee break rooms, and other leisure spaces where individuals spend significant time.
You can read the newsletter, only available in German, here.