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By Pascale Gelly

In an answer to a query brought by the online magazine, the CNIL (the French data protection authority) clarified what should be considered “informed consent” (opt in). In cases where a business intends to share personal data with other business partners, the individuals concerned should be put in a position to identify all data recipients. “The list should be up to date at the time the Internet user’s consent is collected and the Internet user should, as the case may be, be informed on the data collection form (or on the partners list if it is linked via a hyperlink) of the fact that the list may evolve.

Pascale Gelly of the French law firm Cabinet Gelly can be reached at


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