QQuestions:
Are Driver Licenses regarded as personal data of identifiable persons? Can a government agency refer a person’s penalty data to another agency by way of data combination? Does such reference require the authorization of the PDPB?
AReply

A driver License bears the holder's name, photo and other information, which are personal data of an identifiable person. According to Article 3 and Article 4(1)(1) of Law 8/2005 (Personal Data Protection Act), the processing of such data is subject to the provisions of the Act. Where a government agency correlate personal data to another agency by combination, unless it is provided for in law or organic regulations, and that the recipient agency is authorized to process such data, otherwise the transferring agency must seek the authorization of the PDPB.

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