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Re:GDPR: Removing Monal from the EU by poizan42 on Friday May 18, 2018 @03:56AM (#17099471)
I'm not seeing any interpretation being done here, but judge for yourself. Here is what the GDPR actually says (Art. 37 Designation of the data protection officer):

> (1) The controller and the processor shall designate a data protection officer in any case where:

> a) the processing is carried out by a public authority or body, except for courts acting in their judicial capacity;

> b) the core activities of the controller or the processor consist of processing operations which, by virtue of their nature, their scope and/or their purposes, require regular and systematic monitoring of data subjects on a large scale; or

> c) the core activities of the controller or the processor consist of processing on a large scale of special categories of data pursuant to Article 9 or personal data relating to criminal convictions and offences referred to in Article 10.

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