The Israeli Privacy Protection Authority has published today (28/11) an opinion regarding the question of whether the data protection requirements set out under the Israeli Privacy Protection Law apply to a digital database that contains individuals' names and email addresses ("the Opinion").
The Privacy Protection Authority has clarified that a database that contains individuals' names and email addresses would be regarded as "personal information" per the Law.
More importantly, while Article 7(2) of the Law excludes "collection that includes only the name, address and method of communication" from the definition of a "database" under the Law (subject to fulfillment of certain conditions), it was clarified that a database containing individuals' names and email addresses would not fall within this exclusion, given that email addresses may, in some instances, reveal additional information relating to the individuals (such as private matters or a persons' beliefs).
The practical outcome of this Opinion is that databases containing names and email addresses would be subject to the data protection requirements set out under the Law, including the duty to register a database (subject to the fulfillment of one of the conditions set out under Article 8(c) of the Law).
It should be also clarified that this requirement would apply, inter alia, to databases gathered or recorded by Israeli businesses with respect to their customers and suppliers (both in Israel and abroad).
We would be happy to provide further advice and recommendations concerning the new regulatory Opinion and its practical implications.
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