Ms Helen Dixon:

Again, one would have to trace through all the principles of the GDPR and examine the 2018 Act. Clearly, there is a very specific context, as the Senator referred to data collected and compiled for electoral activities. There is provision in the 2018 Act that allows for it, although it is not a free for all. First, one would have to check if that provision created a legal basis sufficient for what is taking place. Second, that provision does not eliminate, as the Senator said, the obligation on any controller to ensure transparency with respect to data subjects and to ensure those data subjects will be able to exercise all rights that may be relevant to them under the GDPR. It is not possible to give a definitive answer because the devil will be in the detail of how it is done. It is theoretically possible to legitimatise it. Equally, it is possible it would fail in actual implementation on every single one of the principles and, therefore, it would be important to step through it in the actual detail in order to answer the Senator's question definitively.