If a person who has already been deleted is detected during import or manual capturing, always check whether
- capturing the person again stands in the way of the deletion request (for example, time period of deletion),
- the person is making a “test” to check if they are really deleted,
- the person would expressly like to be captured again despite their deletion request.
The legal basis for re-importing or creating the person must always be clarified and, if necessary, agreed with the data protection officer. If there is no clear legal basis, the person may not be imported or created.
If you capture the person again, it is necessary to proceed in compliance with the GDPR (consent, etc.) as with a new contact. The legal basis must be clarified clearly or creatively with the person at the latest when contacting them on the basis of Art. 6 GDPR (lawfulness of processing).