If you decide to obtain your client’s approval via a written document, you must do so using precise, easy-to-understand terminology. It states, however, that a data processor must be able to provide proof that a person has given consent for the collection of their personal data. The GDPR does not refer to consent being either implied or expressed. The Australian Privacy Principles require an individual to authorise, whether express or implied, the collection of their personal data. Your client also has the right to dispatch their personal data to any other business or institution without interfering with the company they initially provided their data. Your client has the right to request that you hold their personal information in a data processor, in a commonplace, plus in an organised and machine-readable format.
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