CNIL, re-use of data: the compatibility test covers sharing with third parties (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data, carrying out the necessary additional tests and verifications', 7 June 2024 (courtesy translation))
The CNIL says in terms that sharing data with third parties for a different purpose needs the compatibility test. Licensing records to an AI buyer is exactly that, unless the holder told people about it when collecting.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“The obligation to carry out this "compatibility test" applies to the further processing of data (within the meaning of Article 6.4 GDPR), i.e.: which have not been foreseen or brought to the attention of data subjects when collecting the data; which are carried out by the same controller who decides to re-use data for a purpose distinct from the purpose for which it was collected, including when it comes to publishing it on the Internet or sharing it with third parties for re-use for another purpose.”
Where it was read
Also read from the same source
- CNIL, data acquired from a third party: the supplier must check compatibility and may set the limits by licence (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data', 7 June 2024, section on datasets acquired from a third party)
- CNIL, re-use of data: even a compatible purpose needs a lawful basis and information to people (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data, carrying out the necessary additional tests and verifications', 7 June 2024 (courtesy translation))
- CNIL, re-use of data: the research presumption and why machine learning is not 'statistical' (CNIL, 'Ensuring the lawfulness of the data processing - In case of re-use of data', 7 June 2024 (courtesy translation))
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide