- The BayLDA clarified that the affixing of doorbell signs is not (partially) automated data processing and therefore the GDPR is not applicable in accordance with Art. 2.
- If the GDPR were applicable, the installation of doorbell signs would generally be covered by a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, subject to exceptions.
- The BayLDA described the assertion that doorbell signs are inadmissible without consent as nonsensical and contradictory to its legal opinion.
In recent days, the media have repeatedly reported that around 200,000 doorbell signs are to be removed in Vienna for data protection reasons (e.g. at heise.de: “Anonymous living with DSGVO”). Apparently, there were also similar views in Germany. The Bavarian supervisory authority, the BayLDA, therefore saw itself to a Clarification initiatedThe installation of doorbell signs is neither fully nor partially automated data processing, which is why the GDPR is not applicable according to Art. 2. If it were, this process would – exceptions reserved – be covered by a legitimate interest within the meaning of Art. 6 (1) lit. f DSGVO. The view that the installation of doorbell signs is impermissible without consent is simply “nonsensical”.