What happened
On a reference from the Austrian Federal Administrative Court, the Court held that the right under the first sentence of Article 15(3) to obtain a copy of the personal data undergoing processing means the data subject must be given a faithful and intelligible reproduction of all of those data. The right entails obtaining copies of extracts from documents, of entire documents, or of extracts from databases containing those data, where providing such a copy is essential to enable the data subject to exercise effectively the rights the Regulation confers, account being taken of the rights and freedoms of others. The Court noted that a purely general description of the data, or a reference to categories of data, does not answer to the ordinary meaning of a copy, and that contextualisation may be necessary where data are generated from other data or result from empty fields. It also held that the word information in the third sentence of Article 15(3) refers only to the personal data of which a copy must be provided.
What changes at the desk
The table of field names that many teams still send is not a copy. Work from the data outward: for each item, ask whether a reader could understand it without the document around it, and where they could not, the extract or the document goes into the bundle with everyone else's data redacted out of it. The rights of others are a reason to redact a document and not a reason to withhold it, which is the balance the Court left in place rather than removed.
Primary source
RulingEuropean Union4 May 2023
Elsewhere on the record
Entries from the same jurisdiction, or on the same kind of document. Each one links the text it was written from, as this one does.