What should you take into account when disclosing personal data in hobby activities?

Circumstances may arise in which you need to disclose personal data to third parties in connection with hobby activities. You must notify the data subjects in advance of the disclosure of personal data and of what data concerning them will be disclosed to third parties.

You always need a legal basis for the disclosure of personal data, as for any other form of processing. If the hobby organiser’s right to disclose the data subject’s data to third parties has not been provided for by law, the hobby organiser must ask for the data subject’s specific consent for the disclosure. In such situations as well, the hobby organiser must inform the data subjects of how their personal data will be used and for what purposes. Data subjects must be informed in advance of the disclosure of data to third parties.

Please remember that the telephone numbers and addresses of some data subjects may be secret. Informing the data subjects of the disclosure of personal data is particularly important in such cases. A person can also have a non-disclosure for personal safety reasons or may be otherwise unwilling to have their data shared with other club members or the hobby organiser’s partners.

If the hobby organiser discloses the data subjects’ personal data for commercial purposes or for cooperation with commercial partners, it must consider the lawfulness of the processing, especially if it intends to disclose the personal data of children for commercial purposes.

Can a hobby organiser publish the results of individual club members, e.g. in a competition or skill contest?

Informing the data subjects and the legal basis for publication need to be taken into account when publishing the competition or skill contest results of individuals, e.g. on the hobby organiser’s website. It is the controller’s responsibility to assess the lawfulness of the publication. In any case, the participants in the competition must be informed that the results will be published.

If the hobby organiser will publish the results itself, it must first consider which legal basis it will use for the publication. In some cases, the publication can be based on the controller’s legitimate interest. The data subject then has the right to object to the publication of their personal data. The controller must inform the contestant that their data will be published and that they have the right to object to the processing of their personal data.

The results could also be published based on the data subject’s consent, in which case the hobby organiser could ask the contestants for their specific consent to the publication of personal data already when registering for the competition. The data subject can withdraw their consent at any time, upon which the data must be erased.

Clubs and associations must consider on a case-by-case basis whether data can be published based on the controller’s legitimate interest or whether the data subject’s consent is required.