Online services became part of our everyday life. The provision of online services, in almost all cases, goes hand in hand with data processing. On the one hand, we provide our data intentionally to the service providers when we decide to use services online but in other cases, data are collected when we use the services. Due to the nature of online services, some of the general data protection rules shall be shaped and interpreted accordingly to be applicable in the context of online services. Two new guidelines have been published recently that may help in interpreting the data protection requirements in connection with the provision of online services. (Both guidelines were published in draft versions for public consultation purposes.)
The first guidelines were published by the European Data Protection Board (EDPB) on the processing of personal data under Article 6(1)(b) of the GDPR in the context of the provision of online services to data subjects (Guidelines 2/2019).
The second guidelines were issued by the UK’s Information Commissioner's Office (ICO) on age appropriate design, as a code of practice for online services.
Both guidelines make clear that the term “online services” is applied in the meaning of “information society services” as defined in Directive 2015/1535 (Article 2). Information society services mean “any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.”