What is the difference between personal data vs. bibliographic metadata

Secondary declaration metadata may contain title or product metadata, which may include information such as an author name, the personal or artistic names of content creators or musicians.

The question of whether bibliographic data, such as the author’s name, are considered “personal data” under the General Data Protection Regulation (GDPR) is highly dependable on the specific context and on how the data is collected, processed, and used.

The GDPR defines “personal data” as broadly as possible, including any information relating to an identified or identifiable natural person. An identifiable natural person may be identified directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier. Identification may also happen due to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

In general, bibliographic data such as an author name would likely be considered personal data under the GDPR regime if it can be linked to an individual person, and the data is being processed.

However, if the bibliographic data is published and available in public domain, this act would represent consent to the specific use. The GDPR states that data made public by the data subject is not subject to protection anymore.

REPORT: Impact of the General Data Protection Regulation and the national personal data protection legislation on the copyright infrastructure

"When a natural person gives their consent in a context defined in the copyright legislation, the author gives their consent to the publication of the work, and the author's name is used in connection with the work to enforce and protect the copyright. 

When we are talking about consent in connection with the data protection legislation, consent is defined differently, and a natural person gives consent to the processing of their personal data for a specific purpose and the consent must meet specific requirements laid down in the law."

Source: Ministry of Education and Culture, Publications of the Ministry of Education and Culture, http://urn.fi/URN:ISBN:978-952-263-781-9

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