A call-centre staffer asks who the “data subject” is when a CRM row concerns a deceased relative. Which GDPR-focused answer is correct?
Select an answer to reveal the explanation.
Short Explanation
GDPR’s spotlight is on living people. A deceased relative is generally outside that GDPR “data subject” frame, though national law might still say something about the dead. The living customer in the next field is the classic data subject.
Full Explanation
Article 4(1) GDPR centres on natural persons, and Recital 27 clarifies that the Regulation does not apply to the personal data of deceased persons, leaving room for Member State rules. The data subject is the natural person the personal data relates to. Legal persons are not data subjects in the GDPR sense, and supervisory authority staff are not the exclusive data subjects.