Is it necessary to inform subjects who have already given their consent to the previous Spanish Personal Data Protection Act (the LOPD) about the new aspects required by Articles 13 and 14 of the GDPR?
The GDPR expands on the matters about which data subjects must be informed and modifies some aspects of how this information should be provided.
However, with respect to data collected before 25 May 2018, it is not mandatory to provide new information with the requirements set forth in the GDPR. This obligation only applies to data collected after that date. However, if circumstances permit, a good practice may be to use communications with data subjects to inform them of the new issues raised by the GDPR.