Court of Justice 1 February 2018, C-25/17 (Proceedings brought by Tietosuojavaltuutettu.)

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Advocate General Mengozzi opines that door-to-door proselytising by members of a religious community does not constitute a purely personal or household activity, thereby falling within the scope of Directive 95/46/EC. The Opinion suggests that manual notes collected during such activities constitute a filing system if structured by geographical or other criteria allowing easy access for subsequent visits. Furthermore, a religious community may be classified as a joint controller if it exerts de facto influence over the purposes and means of data processing, regardless of whether it has direct access to the data.AI