Court of Justice 4 September 2025, C-312/24 (CL v Prokuratura na Republika Bulgaria.)

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Advocate General Szpunar opines that Regulation (EU) 2016/679 (GDPR) applies to a public authority's storage of criminal investigation data in an official's personnel file when such processing pursues administrative or employment purposes rather than the prevention or prosecution of crimes. The Opinion suggests that storing data regarding a discontinued investigation in a police officer's file lacks a sufficient legal basis under Article 6(1)(c) and (3) of the GDPR, as the mere nature of the officer's duties does not establish a proportionate objective of public interest. Furthermore, the Advocate General concludes that Directive 2000/78/EC does not apply to alleged discrimination based on an individual's status as a former criminal suspect, as this does not constitute a protected ground under the directive.AI