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Metadata is
personal data

A name and a location inside a file are personal data whether or not anyone meant to put them there.

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Intent does not change the classification

GDPR defines personal data by what it is, not by whether it was disclosed deliberately. An author name, a device identifier and a set of coordinates embedded in a shared file are personal data being processed, and they fall inside the same obligations as any field in a database.

Where it tends to matter in practice

Files published on a website. Documents attached to emails leaving the organisation. Photographs of staff or premises. Data shared with a processor or a partner. Responses to subject access requests, which are frequently exported as documents carrying the properties of whoever compiled them.

Transfers and third-party tools

Uploading a document to an online processing service is itself a transfer to a third party, and possibly out of the region. That is a separate assessment to make before using any cloud-based cleaning tool. Processing entirely in the browser avoids the question, because nothing is transferred.

Not legal advice

This is a description of a common gap, not a compliance opinion. Your data protection officer or counsel should decide what your obligations actually are.

Common questions

Is EXIF data personal data under GDPR?

Where it identifies an individual, directly or in combination with other information, it generally falls within the definition. Take advice on your specific case.

Does uploading a file to a cleaning tool count as processing?

It involves transferring the file to a third party, which typically requires its own assessment. Processing locally in the browser avoids the transfer.

Is this page a compliance tool?

No. It is a free utility. Treat it as one input to a process your own advisers define.

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