Precedent corpus / DPC (Ireland)
Apple Distribution International Limited
DPC (Ireland) case IN-20-39-1, decided . No monetary penalty.
We have not checked whether this decision was appealed. This is not a statement that no appeal exists.
No ConsentMark grade rests on this decision. It is published here because it is relevant enforcement, not because it bears on what a browser does before consent.
What the regulator decided
Apple retained a hashed version of a complainant's email address after processing an Article 17 erasure request and did not inform the data subject of the retention, the legal basis or the recipients of the data, breaching the transparency obligations in Article 13(1)(c) and 13(1)(d) GDPR; the retention itself was lawful under Article 6(1)(f) but the non-disclosure was not.
Primary source
Regulator-owned URL. Quote this in legal briefs and academic citations.
https://www.dataprotection.ie/sites/default/files/uploads/2024-08/Inquiry-into-Apple-Distribution-International-Limited-Final-Decision-March-2024-EN.pdfConsentMark interpretation
Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.
Reprimand under Article 58(2)(b) GDPR; no administrative fine. Cite when a service hashes an email or identifier post-erasure for suppression-list purposes and does not surface the retention in its privacy notice - the hashing does not exempt the controller from Article 13 transparency.
Verification trail
Checked against the primary source on 27th May 2026. Next review 27th November 2026.
Cite this case
@misc{consentmark-precedent-dpc-in-20-39-1,
author = {{ConsentMark}},
year = {2024},
title = {DPC (Ireland) IN-20-39-1 - Apple Distribution International Limited},
howpublished = {\url{https://www.consentmark.com/precedent/dpc-in-20-39-1}},
note = {ConsentMark methodology v7.8.1}
}ConsentMark. (2024, March 7). DPC (Ireland) IN-20-39-1 - Apple Distribution International Limited. Methodology v7.8.1. https://www.consentmark.com/precedent/dpc-in-20-39-1[DPC (Ireland) IN-20-39-1 - Apple Distribution International Limited - ConsentMark](https://www.consentmark.com/precedent/dpc-in-20-39-1)DPC (Ireland) IN-20-39-1 - Apple Distribution International Limited - ConsentMark, 2024-03-07, methodology v7.8.1, https://www.consentmark.com/precedent/dpc-in-20-39-1