Facebook’s latest revelation that up to 50m user accounts may have been compromised once again highlights privacy issues around using social media for business or personal use.

We’ve already discussed the security and privacy issues around using a company Facebook page, and this latest breach will have Data Protection Officers and other security professionals once again considering their company policy around social media.

Article 25 of the EU General Data Protection Regulation (GDPR) requires Data Protection by Design and Default. 

1. Taking into account the state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, the controller shall, both at the time of the determination of the means for processing and at the time of the processing itself, implement appropriate technical and organisational measures, such as pseudonymisation, which are designed to implement data-protection principles, such as data minimisation, in an effective manner and to integrate the necessary safeguards into the processing in order to meet the requirements of this Regulation and protect the rights of data subjects.

2. The controller shall implement appropriate technical and organisational measures for ensuring that, by default, only personal data which are necessary for each specific purpose of the processing are processed. That obligation applies to the amount of personal data collected, the extent of their processing, the period of their storage and their accessibility. In particular, such measures shall ensure that by default personal data are not made accessible without the individual’s intervention to an indefinite number of natural persons.

Recital 78 provides further clarification:

When developing, designing, selecting and using applications, services and products that are based on the processing of personal data or process personal data to fulfil their task, producers of the products, services and applications should be encouraged to take into account the right to data protection when developing and designing such products, services and applications and, with due regard to the state of the art, to make sure that controllers and processors are able to fulfil their data protection obligations.

Given the number and scale of Facebook breaches that are publicly known, could a Data Protection Officer reasonably conclude that the use of Facebook wasn’t a risk to the personal data of their employees, clients, prospects or just ‘fans’ of the brand?

Could encouraging clients and prospects to follow, like, rate or comment on their Facebook company page be a breach of the GDPR?

Should a Facebook Page or Group be part of your customer support strategy?

Should you allow users to sign in to your app using their Facebook – or other social media – credentials?

While Facebook has to be accountable for the personal data that it stores, would a company that encouraged the use of Facebook – knowing its vulnerabilities and history of breaches – be following best practice to ensure the privacy of its customers personal data?

While we await case law to see how the finer points of the GDPR will be interpreted by the courts, you don’t need to be a legal expert to see the potential risks for companies using public social media to communicate and engage with consumers, employees, suppliers and other stakeholders.

The tough question for DPOs is – “What are you going to do about it?”

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