CNIL.
COMMISSION NATIONALE
INFORMATIQUE & LIBERTES
The President
Examination of the case: Paris, on 2 3' AOUT 2019
Our Ref.: MLD/XD/SGE/DAU/CM192505
Case no. 19005906
(to be referenced in all correspondence)
·.r:
Dear Mr. Director General,
This is further to the exchanges that took place between the CNIL's services and the Legal
department of the (hereinafter the "
") in the framework of the examination of the complaint of , which
was transmitted to the CNIL by the German data protection authority of Saxony-Anhalt pursuant to
the provisions of Article 5 6 . 1 of the General Data Protection Regulation (GDPR).
had lodged a complaint with his national data protection authority against the
which would not have granted his objection request to receive direct marketing and his
request to obtain access to data concerning him.
Those exchanges lead me, in agreement with other data protection authorities concerned by the
processing for direct marketing purposes and for management of customers data purposes, to proceed
to the closure of this complaint.
Indeed, in view of the materials submitted, I note that 's requests have been
granted.
I take note that 's objection request dated July 14th, 2 0 1 8 has been taken into
1
account by your services on July 19 h, 2 0 1 8 . At this time, the complainant's email address has been
erased from your direct marketing tools and an unsubscribe confirmation message has been sent to
him.
Nonetheless, I would like to draw your attention on the enhancements that must be
brought to the unsubscribe process to 's newsletters.
Indeed, the erasure of data from your systems requires a period of 24 to 48 hours to be
effective within your systems.
----------------REPUBLIQUE FRAN<;AISE ---------------
3 P l a c e d e Fontenoy, TSA 8 0 7 1 5 - 75334 P A R I S C E D E X 07 - 0 1 53 73 22 22 - w w w . c n i l . f r
Les tionnees personnel/es necessatres a l'accomplissement des miss/ans de la CNIL sont traltees dans des flchlers destines a son usage exclusif.
Les personnes concernees peuvent exercer leurs drafts lnformat!que et tlbertes en s'adressant au de/egue a fa protection des donnees (DPO) de fa CN!L
via un formula/re en 1/gne ou par courrier postal. Pour en savolr plus: www.cnll.fr/donnees-personnefles.
In view of these elements, I invite you to specify in your unsubscribe confirmation messages
the existence of such period for requests to be effectively taken into account.
Yours Sincerely,