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Exchange of information in relation to the expedition and management of the social tickets
CNS 69/2016
There is not contradiction of the article 28.2 LPAC with the demand for the article 4.9 of the RGPD that the consent manifests through a declaration or a clear affirmative action, because the habilitation would derive from the same LPAC in relation to the e letter) of the article 6.2 of the RGPD. However, the application of the foreseen mechanism in article 28 has to limit itself to the administrative procedures of the entities that have the condition of public administrations. The exchange of data among the administration that it has the information about the titles of numerous or monoparental family or about the situation of unemployment and the entity that sends the ticket cannot found in the b letter) of the article 6.1 of the RGPD since it is not an exchange strictly necessary for the expedition. Regarding the letters c) and e) of same article 6.1 RGPD yes that they could fit out the exchange, whenever it is in a rule foreseen with rank of law that is concrete, precise and predictable.
29/11/2016
Total number of pages: 5