Transparency matters: WhatsApp fined EUR 225 million for violating transparency obligations under the GDPR

On 2nd September 2021 the Irish Data Protection Commission (”DPC”) imposed its biggest fine to date on WhatsApp, the messaging app owned by Facebook. In its reasoning (available here) the DPC considered both: the information provided by WhatsApp to its users, and perhaps more importantly  the lack of information provided to non-users.  Namely, it was…