It should be noted that this isn't a legal decision. This is a guideline on how the Dutch DPA sees it, and although it carries some weight the issue won't be s

It should be noted that this isn't a legal decision. This is a guideline on how the Dutch DPA sees it, and although it carries some weight the issue won't be settled unless and until a court makes a formal decision. My 2c is that the Dutch DPA's guideline is wrong and extremely restrictive.