Opinions can be Incorrect! In our Opinion. On the accuracy principle in data protection law

Abstract

The GDPR contains an accuracy principle, as most data privacy laws in the world do. In principle, data controllers must ensure that personal data they use are accurate. Some have argued that the accuracy principle does not apply to personal data in the form of opinions about data subjects. We argue, however, from a positive law perspective, that the accuracy principle does apply to opinions. We further argue, from a normative perspective, that the accuracy principle should apply to opinions.