All appeals are dismissed.

The grounds of appeal are examined.

Article 17(1)1 of the Personal Information Protection Act provides that a person who provides personal information to a third party without the consent of the subject of information in violation of Article 17(1)1 of the Personal Information Protection Act, and Article 71(1)1 of the Personal Information Protection Act provides that a person who provides personal information to a third party without the consent of the subject of information, and a person who knowingly receives personal information

On the other hand, the Personal Information Protection Act, which does not require the consent of the subject of information in Article 26, determines the delegation of personal information management affairs to the personal information manager.

In light of the language and purport of the aforementioned legal provision, “the provision of personal information to a third party” under Article 17 of the Personal Information Protection Act means a case where personal information is transferred for the performance of duties and interests of the recipient of the information beyond the scope of the original purpose of collection and use of personal information, and “the entrustment of management” of personal information under Article 26 of the Personal Information Protection Act means a case where personal information is transferred for the performance

In the entrustment of personal information management, the trustee does not have an independent interest in the management of personal information except for the payment of the price for the entrusted affairs by the truster, and handle personal information only within the scope entrusted under the supervision and supervision of the provider of information. Thus, it does not constitute a “third party” under Article 17 of

Whether an act is a provision or entrustment of management of personal information is the purpose and method of acquiring personal information, whether to give or receive remuneration, whether to substantially supervise a trustee, the impact on the necessity of protecting personal information of the subject of information or the user, and the person who needs to use such personal information is actually who is.