Provides GDPR Article 14 guidance for indirect personal data collection from third parties, including timing (within 1 month), required disclosures, source details, categories of data, and exemptions.
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GDPR Article 14 applies when a controller obtains personal data from a source other than the data subject — such as from third-party data brokers, publicly available sources, other controllers, or through automated observation by third parties. The controller must still provide the data subject with comprehensive information about the processing, but the timing and content requirements differ f...
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GDPR Article 14 applies when a controller obtains personal data from a source other than the data subject — such as from third-party data brokers, publicly available sources, other controllers, or through automated observation by third parties. The controller must still provide the data subject with comprehensive information about the processing, but the timing and content requirements differ from Art. 13.
All elements required under Art. 13(1)(a)-(f) and Art. 13(2)(a)-(g) PLUS:
| Element | Article | Description |
|---|---|---|
| Categories of personal data | Art. 14(1)(d) | The categories of personal data concerned (not required under Art. 13 because the subject already knows what they provided) |
| Source of data | Art. 14(2)(f) | From which source the personal data originate, and if applicable, whether it came from publicly accessible sources |
The controller must provide the information:
The earliest applicable deadline governs.
Art. 14(1)-(4) shall not apply where and insofar as:
| Scenario | Data Source | Categories | Timing Obligation |
|---|---|---|---|
| Client employee data received from employer client | Employer (another controller) | Name, email, job title, access permissions | Within 1 month of receipt, or at first communication |
| Companies House / public registry data | Publicly accessible source | Director names, registered address, filing history | Within 1 month; note public source in notice |
| Credit reference agency data | Credit reference agency (Experian, Equifax) | Credit score, payment history, financial indicators | At first communication or within 1 month |
| Referral from existing client | Existing client | Name, email, company | At first communication with referred person |
| Data enrichment from third-party provider | Data enrichment provider | Firmographic data, industry classification | Within 1 month of enrichment |
Apply the earliest applicable deadline from Art. 14(3)(a)-(c):
[Data Received from Third Party]
│
▼
[Will data be used to contact the subject?]
├── Yes ──► Notify at or before first communication
└── No ──► [Will data be disclosed to another recipient?]
├── Yes ──► Notify before or at disclosure
└── No ──► Notify within reasonable period (max 1 month)
The notice must contain all elements specified in Art. 14(1) and (2). Use the following structure:
Before deciding not to provide Art. 14 information, assess each exemption strictly:
| Exemption | Assessment | Documentation Required |
|---|---|---|
| Art. 14(5)(a) — Already has info | Verify the subject has received materially equivalent information from another source | Record the source and date of prior information |
| Art. 14(5)(b) — Impossible/disproportionate effort | Conduct and document proportionality assessment considering: number of data subjects, age of data, compensatory measures available | Written proportionality assessment, approved by DPO, with compensatory measures (e.g., publish information on website) |
| Art. 14(5)(c) — Law requires acquisition | Identify the specific legal provision | Citation of the provision |
| Art. 14(5)(d) — Professional secrecy | Identify the statutory obligation of secrecy | Citation of the provision |
The EDPB Guidelines on Transparency (WP260 rev.01) state that the Art. 14(5)(b) exemption should be interpreted restrictively and that the mere inconvenience or cost of providing information is not sufficient to constitute "disproportionate effort."