Article 30, section 5:

"5. The obligations referred to in paragraphs 1 and 2 shall not apply
to an enterprise or an organisation employing fewer than 250 persons
unless the processing it carries out is likely to result in a risk to
the rights and freedoms of data subjects, the processing is not
occasional, or the processing includes special categories of data as
referred to in Article 9(1) or personal data relating to criminal
convictions and offences referred to in Article 10."

I think this makes the mailing list excempt from the need to keep
detailed records. Under the presumption that less than 250 people
manage the mailing list, of course.

This only applies to the need for a data controller and processor, not the general duties under the GDPR.


"This Regulation applies to the processing of personal data wholly or partly by automated means and to the processing other than by automated means of personal data which form part of a filing system or are intended to form part of a filing system." (art 2)


'‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;' (art 4-1)


'processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; (art 4-2)

Whether an email list, where it may be argued that no processing of personal data is done, falls under that scope is, at least, debatable...

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