CLAIM-2026-09-04-07

GDPR Article 4(2) defines processing as "any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction" — naming retrieval and consultation, and setting no threshold of cost or effort.

Why it matters

Retrieval and consultation are enumerated operations with no cost threshold attached. That is the whole reason a cheap cache read is not outside the Regulation.

Sources

• intersoftco2026definitio