The Privacy Protection Authority has published guidance on the transfer of ownership in a database

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The Privacy Protection Authority has published guidance on the transfer of ownership in a database

In December 2024, the Privacy Protection Authority published new guidance on the transfer of ownership in a database, emphasizing that changes in the identity of the database controlling owner may afect the rights of the data subjects.

In December 2024, the Privacy Protection Authority published new guidance on the transfer of ownership in a database. As part of the new guidance, the Authority emphasized several issues concerning the transfer of ownership in databases, considering the fact that changes in the identity of the database controlling owner may be significant for the data subjects and may affect their rights.

The new database owner may use the information stored in the database only for the original purpose for which it was provided, and is subject to all obligations which applied in this regard to the original database owner (the transferor). It is clarified that the purpose of using the information cannot change as a result of the transfer of ownership.
Whenever ownership in database is transferred to a new database owner, the transferor or transferee of the database must inform the data subjects of the transfer.
If as a result of such transfer of ownership, changes are expected in the purposes of the database and the uses of the information by the new database owner, the transfer of ownership and the additional uses will be made subject to and only after the informed consent of the data subjects has been obtained.

The Authority emphasizes that in cases in which the characteristics of the new database owner materially differ from those of the original database owner in a manner which may significantly affect the rights of the data subjects or which may significantly veer from their expectations regarding the circumstances in which the information is collected and used, or if it can be assumed that the data subject would not have engaged the services of the new database owner - the data subject's consent must be obtained in advance, even if the original purpose of using the information has not been changed.

For the full text of the Authority's Privacy Protection guidance (in Hebrew) Click here.

Note: This overview provides concise information for informational purposes only. It does not constitute legal advice and should not be relied upon as such.