Back to basics: The European Court of Justice further defined the concept of personal data and the scope of the right of data subjects to access it

The Court of Justice has ruled that a legal analysis contained in an administrative document prepared in the specific context of applications for residence permits in The Netherlands is not personal data as such although it may contain personal data that data subjects then have the right to access. The Court also ruled that for the right of access by data subjects to their own personal data provided for in Article 12(a) of Directive 95/46 to be complied with, it suffices that the applicant be in possession of a full summary of his own personal data in an intelligible form without necessarily being entitled to obtain a copy of the personal data undergoing processing.