I received an address file from a supplier. Do I have to inform all those people?

Yes, as a rule. Paragraphs 1 and 2 apply precisely to data you did not obtain from the person, and paragraph 3 says you do this within a reasonable period and at the latest within one month, or already at the first contact if you use the data to approach those people. You also state the source of the data (paragraph 2(f)). Only the exceptions in paragraph 5 can relieve you of this, for example where the people already have the information.

When can I say that informing would involve a disproportionate effort?

Paragraph 5(b) contains that exception, with archiving in the public interest, scientific or historical research and statistics as examples, and cases where informing would render impossible or seriously impair the objectives of the processing. Recital 62 names the number of data subjects, the age of the data and the safeguards you adopt as factors. If you rely on this exception, you must still take appropriate measures to protect the data subjects, including making the information publicly available.

What is the difference from Article 13?

Article 13 applies when you collect the data from the person directly; Article 14 applies when they come from elsewhere. The content is very similar, but Article 14 additionally requires the categories of data (paragraph 1(d)) and the source (paragraph 2(f)), because otherwise the person does not know what you hold about them. The timing also differs: not at collection but within one month or at the first contact (paragraph 3), and paragraph 5 contains more exceptions.

Article 14: Information to be provided where personal data have not been obtained from the data subjectAI-relevant

Praxikon tracks Article 14 (Information to be provided where personal data have not been obtained from the data subject) under the GDPR, alongside the EU AI Act, citing the source for every statement.

Chapter IIIIn force since 25-05-2018

Article 14 sets out the duty to inform where you obtain personal data not from the person directly but, for example, from another organisation, from public sources or through a purchased list. Even then the person must be told who you are, for what purposes and on which legal basis you use the data, which categories of data are involved and who receives them (paragraph 1), plus the retention period, the rights, the source of the data and the existence of automated decision-making (paragraph 2). Because there is no contact moment at collection, paragraph 3 sets its own timeline: within a reasonable period and at the latest within one month, or earlier if you contact the person or disclose the data. Paragraph 5 contains exceptions, for example where the person already has the information, where informing is impossible or would involve a disproportionate effort, or where a statutory obligation of professional secrecy applies. The article exists because people should also know what happens to their data when they did not hand them over themselves (recitals 60 and 61), while recital 62 recognises that informing is not reasonable in every case.

Key term: Indirect collection: data you obtain not from the person directly but from another organisation or from public sources; even then you must inform that person

Directly affects:controllerdata subjectdata protection officer

Praxikon’s reading of the text and the recitals; the official text below prevails.

AI Act intersection

Information obligation at indirect collection overlaps with transparency requirements (Art. 13 and 50 AI Act), particularly for AI training on public data.

AI Act Art. 13 →AI Act Art. 50 →

Official text

Where personal data have not been obtained from the data subject, the controller shall provide the data subject with the following information: (a) the identity and the contact details of the controller and, where applicable, of the controller's representative; (b) the contact details of the data protection officer, where applicable; (c) the purposes of the processing for which the personal data are intended as well as the legal basis for the processing; (d) the categories of personal data concerned; (e) the recipients or categories of recipients of the personal data, if any; (f) where applicable, that the controller intends to transfer personal data to a recipient in a third country or international organisation and the existence or absence of an adequacy decision by the Commission, or in the case of transfers referred to in Article 46 or 47, or the second subparagraph of Article 49(1), reference to the appropriate or suitable safeguards and the means to obtain a copy of them or where they have been made available.

In addition to the information referred to in paragraph 1, the controller shall provide the data subject with the following information necessary to ensure fair and transparent processing in respect of the data subject: (a) the period for which the personal data will be stored, or if that is not possible, the criteria used to determine that period; (b) where the processing is based on point (f) of Article 6(1), the legitimate interests pursued by the controller or by a third party; (c) the existence of the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability; (d) where processing is based on point (a) of Article 6(1) or point (a) of Article 9(2), the existence of the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal; (e) the right to lodge a complaint with a supervisory authority; (f) from which source the personal data originate, and if applicable, whether it came from publicly accessible sources; (g) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The controller shall provide the information referred to in paragraphs 1 and 2: (a) within a reasonable period after obtaining the personal data, but at the latest within one month, having regard to the specific circumstances in which the personal data are processed; (b) if the personal data are to be used for communication with the data subject, at the latest at the time of the first communication to that data subject; or (c) if a disclosure to another recipient is envisaged, at the latest when the personal data are first disclosed.

Where the controller intends to further process the personal data for a purpose other than that for which the personal data were obtained, the controller shall provide the data subject prior to that further processing with information on that other purpose and with any relevant further information as referred to in paragraph 2.

Paragraphs 1 to 4 shall not apply where and insofar as: (a) the data subject already has the information; (b) the provision of such information proves impossible or would involve a disproportionate effort, in particular for processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the conditions and safeguards referred to in Article 89(1) or in so far as the obligation referred to in paragraph 1 of this Article is likely to render impossible or seriously impair the achievement of the objectives of that processing. In such cases the controller shall take appropriate measures to protect the data subject's rights and freedoms and legitimate interests, including making the information publicly available; (c) obtaining or disclosure is expressly laid down by Union or Member State law to which the controller is subject and which provides appropriate measures to protect the data subject's legitimate interests; or (d) where the personal data must remain confidential subject to an obligation of professional secrecy regulated by Union or Member State law, including a statutory obligation of secrecy.

Source: EUR-Lex, Regulation (EU) 2016/679. Official text, reproduced without modification.

What does this mean for you?

Controller

Where you obtain data through someone else, from a public source or from a supplier, you inform the person yourself within one month, or earlier if you contact that person or disclose the data to another recipient (paragraph 3). You also state the categories of data and the source, and whether it was publicly accessible (paragraph 1(d) and paragraph 2(f)). If you rely on the exception that informing is impossible or would involve a disproportionate effort, for example for processing for archiving in the public interest, scientific or historical research or statistical purposes, you record why and take appropriate measures to protect the data subjects, such as making the information publicly available (paragraph 5(b)).

Data Protection Officer

Your contact details are part of the information the data subject receives (paragraph 1(b)), even where that person did not hand over the data themselves.

Data Subject

Even where an organisation did not obtain your data from you, you are told who processes them, for what purpose, which data are involved and where they come from (paragraphs 1 and 2). This happens at the latest within one month, or earlier at the first contact or when the data are disclosed to someone else (paragraph 3). In a limited number of cases this is not required, for example where you already have the information or where a statutory obligation of professional secrecy applies (paragraph 5).

Compliance checklist

For every processing operation where the data do not come from the data subject directly, the source is recorded, including whether it was a publicly accessible source (paragraph 2(f)).The data subject receives the identity and contact details of the controller and, where applicable, of the data protection officer, the purposes, the legal basis and the categories of data (paragraph 1).The information includes the retention period or its criteria, the legitimate interests where Article 6(1)(f) is relied on, the data subject's rights, the right to withdraw consent and the right to complain (paragraph 2(a) to (e)).Where automated decision-making, including profiling referred to in Article 22, takes place, meaningful information is given about the logic involved, the significance and the envisaged consequences (paragraph 2(g)).The information is given within a reasonable period and at the latest within one month of obtaining the data, or earlier at the first communication with the data subject or the first disclosure to another recipient (paragraph 3).Before the data are processed for another purpose, the data subject is informed about it (paragraph 4).Every reliance on an exception in paragraph 5 is recorded with its justification, and where informing is impossible or disproportionate, appropriate measures are taken, such as making the information publicly available (paragraph 5(b)).

Related recitals

(60)

The principles of fair and transparent processing require that the data subject be informed of the existence of the processing operation and its purposes. The controller should provide the data subjec...

(61)

The information in relation to the processing of personal data relating to the data subject should be given to him or her at the time of collection from the data subject, or, where the personal data a...

(62)

However, it is not necessary to impose the obligation to provide information where the data subject already possesses the information, where the recording or disclosure of the personal data is express...

Cross-references

Art. 6: Lawfulness of processing Art. 9: Processing of special categories of personal data Art. 22: Automated individual decision-making, including profiling Art. 46: Transfers subject to appropriate safeguards Art. 49: Derogations for specific situations Art. 89: Safeguards and derogations relating to processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes

Frequently asked questions

← Art. 13: Information to be provided where personal data are collected from the data subject Art. 15: Right of access by the data subject →

Connections

Themes where this returns

Transparency: informing people

The counterpart in the other law

Case law

EDPS v SRB: pseudonymised data are not always personal data for everyone, but the information duty applies from collection
2025-09-04 · final, Hof van Justitie van de EU (Eerste kamer), Europese Toezichthouder voor gegevensbescherming (EDPS) tegen Gemeenschappelijke Afwikkelingsraad (SRB)
SCHUFA: a credit score on which third parties draw strongly is automated decision-making
2023-12-07 · final, Hof van Justitie van de EU (Eerste kamer), OQ tegen Land Hessen, met SCHUFA Holding AG als interveniënt
Interim relief judge: DPA must redact fine amount when giving an enforcement decision to complainants
2024-05-31 · status not established, Rechtbank Den Haag, voorzieningenrechter (kort geding, team handel)

Guidelines

Guidelines on transparency under Regulation 2016/679
2018-05-25 · final, Article 29 Working Party, bekrachtigd door de European Data Protection Board (EDPB)
Guidelines 03/2026 on web scraping in the context of generative AI
2026-07-07 · under consultation, European Data Protection Board (EDPB)
Guidelines 1/2024 on processing of personal data based on Article 6(1)(f) GDPR (legitimate interest)
2024-10-08 · adopted, European Data Protection Board (EDPB)
Guidelines on Automated individual decision-making and Profiling for the purposes of Regulation 2016/679
2018-05-25 · final, Article 29 Working Party, bekrachtigd door de European Data Protection Board (EDPB)
Guidelines 1/2026 on processing of personal data for scientific research purposes
2026-04-15 · adopted, European Data Protection Board (EDPB)

Enforcement and fines

Dutch DPA fines Uber 824.99 million euros for automated driver deactivation
2026-08-21 · under appeal, Autoriteit Persoonsgegevens
Experian Netherlands fined 2.7 million euros for credit scoring without legal basis or information
2025-10-16 · final, Autoriteit Persoonsgegevens
Clearview AI: 30.5 million euro fine and penalty orders for illegal facial database
2024-05-16 · final, Autoriteit Persoonsgegevens