The Regulation states that client data consist of 3 components (name and surname, phone, e-mail). If there are only 2 components, does data processing take place?


The Regulation states that personal data is any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Thus, there are no other criteria stated in the Regulation for data processing (regardless of the information scope and components). In this case, this will be personal data processing.