CIPP/E Study Guide
IAPP Training · Module 5 - BoK II.C

Module 5 · Data portability (Article 20)

Data portability (Article 20) extends the right of access: the data subject can receive their data in a structured, commonly used, machine-readable format and transmit it to another controller. It is triggered only when processing is based on consent OR contract AND is carried out by automated means - it does NOT apply to legitimate interests, legal obligation or public-task processing.

Data portability (Article 20) lets a person receive their personal data in a structured, commonly used, machine-readable format and transmit it to another controller, with interoperability as the goal. It is an extension of the right of access but is far narrower in scope.

When portability applies

Only triggered when processing is based on consent OR contract AND is carried out by automated means. It does NOT apply to legitimate interests, legal obligation or public-task processing.

Three cumulative conditions for data portability (WP29) - ALL must be met
#ConditionKey point
1Lawful basisProcessed by automated means on the basis of consent or contract (not legitimate interest, legal obligation or public task)
2Source of dataData must be provided by the data subject - given or observed, NOT derived or inferred
3Third partiesExercising it must not adversely affect others' rights and freedoms

Key terms - quick answers

What is “Data portability”?
Article 20: the right to receive personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
What is “Provided by the data subject”?
Data the person actively gave or that was observed from their activity - not data the controller derived or inferred.
What is “Interoperability”?
The goal of portability: enabling data to move usefully between services and controllers.