Opinions can be incorrect! In our opinion: on data protection law’s accuracy principle

Abstract

The GDPR contains an accuracy principle, as most data privacy laws in the world do. In principle, data controllers must ensure the personal data they process 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 suggest, from a normative perspective, that the accuracy principle should apply to opinions.