CJEU - C-12/25
CJEU Advocate General opinion on GDPR applicability to church baptismal registers.
The CJEU Advocate General has opined that a church's baptismal register, even if a physical book, constitutes a filing system under GDPR. This means the regulation applies to manual processing of personal data within such registers. The opinion also addresses the right to erasure, considering exceptions for archiving and historical research, and clarifies what constitutes 'erasure' in this context.
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The lesson from this incident
Full lessonThe CJEU Advocate General's opinion confirms that GDPR applies not only to digital systems but also to manual filing systems, including physical records like church baptismal registers, as long as they are structured to allow retrieval of personal data. This ruling matters because many organizations assume GDPR obligations are limited to electronic data processing, leaving physical records ungoverned and non-compliant. The opinion also clarifies the right to erasure in non-digital contexts, requiring organizations to consider what 'erasure' meaningfully looks like when deletion of a physical record is not straightforward. Exceptions for archiving and historical research add nuance, but do not exempt organizations from establishing lawful bases and documented justifications for retaining such data.