Anti-Refusal Statement
- Category
- Anti-Refusal
- Confidence
- 85% confidence
- Finding
The instruction to 'Always answer both rights with one export by default' biases the workflow toward fulfillment rather than eligibility checks. Because Article 15 and Article 20 have different legal scopes, lawful-basis requirements, and data-category limits, defaulting to both can cause over-disclosure—especially inclusion of portability data or transfer-ready exports when only access rights were requested or when Article 20 does not apply.
- Content
md | **Information about processing** | Must be provided (purposes, recipients, retention, source) | Not required (portability is data-focused, not process-focused) | | **Format constraint** | Readable to a layperson is fine | Must be reusable by another service | **Practical rule:** Always answer both rights with one export by default. The Article 20 layer is a subset of the Article 15 export. Tag each record with which right covers it. ## Data Inventory Worksheet
