He’s making a list
He’s checking it twice
He’s gonna find out who’s naughty or nice…
…but is Santa Claus is in contravention of Article 4 of the General Data Protection Regulations?
So we flew all the way to the North Pole with help from a friendly polar bear, to ask FC and no thanks to some prankster penguins, we tracked him down to get his answer. Father Christmas said that the Elves has been busy back in 2018 pulling together the North Pole Legitimate Interest Assessment, with some guidance from the ICO website and was therefore processing childrens’ personal data using Legitimate Interest as their main legal bases.
Parents of the boys and girls all know why FC uses their data, so he can use it to help decide who's been naughty or nice, allowing him to deliver presents on Christmas Day.
It’s certainly a process that seems to work well as we know that almost all children will receive gifts at Christmas, with only a few naughty ones wondering why they were missed out and whether their personal data was processed at the North Pole.
When FC and the Elves finish working through all the letters, they are filed safely in the North Pole so that they can be sure not to contravene any global Data Privacy regulations.