Regular and systematic monitoring: what does it mean?

Regular and systematic monitoring

What does regular and systematic monitoring mean? GDPR does not provide a specif definition.

However, Recital 24 considers the “monitoring of the behaviour of data subjects” including in this concept every form of online profiling (even for behavioral marketing purposes). Such definition, in any case, does not only include the internet: we must consider online tracking only one of the various ways to monitor the behavior of the data subjects.
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Regular monitoring

What does “Regular” mean in the sentence “Regular and systematic monitoring”? This specific word has to be intended as meaning one or more of the following:

  • Ongoing or occurring at particular intervals for a particular period;
  • Recurring or repeated at fixed times;
  • Constantly or periodically taking place.

Regular and systematic monitoring

Following you can find the analysis of the term “systematic”, that needs to be interpreted as meaning one or more of the following:

  • Occurring according to a system;
  • Pre-arranged, organised or methodical;
  • Taking place as part of a general plan for data collection;
  • Carried out as part of a strategy.

Regular and systematic monitoring: examples

After a brief definition of the sentence as a whole and a deeper analysis of the single terms (“regular” and “systematic”), we can move forward with a few practical examples. Following you can find some activities that can represent a regular and systematic monitoring of the data subjects:

  • e-mail retargeting;
  • providing telecommunications services;
  • data-driven marketing activities;
  • profiling and scoring for purposes of risk assessment;
  • location tracking,…
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