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Are individuals acting as directors or managers “data subjects”? The answer seems logical but corporate documentation is often forgotten in GDPR compliance projects. Directors / managers (“executives”) and shareholders’ personal data are processed by the company, third parties and eventually disclosed to the public so that the company shall be careful to comply with data protection requirements.
Which data and for which purpose?
The first executives’ and shareholders’ personal data coming up in mind are those that are processed in the context of the Laws of 10 August 1915 on commercial companies and of 19 December 2002 on the Luxembourg Trade and Compa-nies Register as well as accountancy and company annual accounts. For this purpose,...
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