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On 9 June 2022, the Advocate General at the CJEU in his Opinion (docket no.
C 154/21) specified the scope of the right of access under article
15(1)(c) of the GDPR. In the initial Austrian case, an individual
had requested information from the postal service about the
disclosure of his data and its recipients. In the response, he only
received information about possible categories of recipients.
According to the Advocate General, the right of access should
include information about the specific recipients of disclosed
Conclusion: This right of access should only be
limited to the indication of categories of recipients if a more
detailed determination is impossible for factual reasons or if the
controller proves that the data subject’s request is manifestly
unfounded or excessive. Should the CJEU rule accordingly, this also
presupposes that the data processing entity indeed also knows all
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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