(CMR) The Ombudsman has ordered the Public Lands Commission to cease collecting excessive personal data of individuals who are organizing wedding ceremonies or other events on public lands and to provide a privacy notice to people when their data is being collected.
According to the order published on November 9 by the Office of the Ombudsman, a member of the public submitted a complaint to the Ombudsman under the Data Protection Act (2021 Revision) (DPA)1 against the Public Lands Commission (PLC). The complainant claimed that the PLC was unnecessarily collecting personal data from marriage officers, their staff, and visiting clients using public beaches for wedding ceremonies and that the frequency with which the personal data was being collected was excessive.
The Ombudsman investigated the matter and found that the PLC had a legal basis for processing personal data, but the PLC contravened the DPA's first and third data protection principles by, respectively, not providing a privacy notice and excessively collecting personal data.
According to the order, due to a lack of response on the part of the PLC, the Ombudsman had to issue an Information Order to obtain information required in the investigation.
The PLC may continue to process personal data that is strictly necessary for such purposes as avoiding scheduling conflicts and ensuring accountability for potential damage to public lands or facilities, such as names and contact details.