1. Facts and Background

Client A, a member of a redevelopment cooperative, requested inspection and copying of "documents and related materials concerning the implementation of the improvement project" pursuant to Article 124, paragraph 4 of the Act on the Improvement of Urban Areas and Residential Environments (the "Urban Improvement Act"). Client A first submitted an information-disclosure request to the competent district office (the project implementer) and, following the office's guidance, submitted a further request to an improvement-project consulting company entrusted with the cooperative-establishment work (the "Entrusted Company"), from which Client A received materials including scanned files of written resolutions. Certain other cooperative members, contending that the personal information of other members contained in those materials had been provided to a third party without consent, filed a criminal complaint against Client A and other related persons for alleged violation of the Personal Information Protection Act ("PIPA"), and an investigation was commenced. Client A retained LKP to respond to that criminal matter.

2. Key Legal Issues

The principal issues were: (i) whether the scanned files of written resolutions provided by the Entrusted Company fell within the scope of "documents and related materials concerning the implementation of the improvement project" under Article 124, paragraph 4 of the Urban Improvement Act and therefore qualified, under Article 15(1)2 and Article 17(1)2 of PIPA ("where there is a special provision in another statute or where the act is necessary to comply with a statutory duty"), for lawful disclosure to a third party without the consent of the data subjects (PIPA Article 71, item 1, constituent-element analysis); (ii) whether Client A's act of requesting information disclosure from the Entrusted Company amounted to acquiring personal information by deception or by other means socially unacceptable as fair (PIPA Article 70, item 2, constituent-element analysis); and (iii) how to organize, on an objective basis, the circumstances showing that the Entrusted Company had been duly entrusted by the project implementer (the competent district office) with authority to handle information-disclosure tasks.

3. Implementation and Outcome

LKP (i) organized, on an item-by-item basis, the relationship between the information-disclosure duty under Article 124, paragraph 4 of the Urban Improvement Act and the "statutory duty" exception under Article 15(1)2 and Article 17(1)2 of PIPA, and the doctrinal basis on which the provision of those materials could be lawfully made without the consent of the data subjects; (ii) consolidated the relevant facts to demonstrate, on an objective basis, that the Entrusted Company had been duly entrusted with information-disclosure authority - including the fact that, before establishment of the cooperative, the competent district office had entrusted to the Entrusted Company all work required for cooperative establishment, the fact that the district office had directed the inquirers to consult the Entrusted Company in relation to information-disclosure requests, and the fact that Client A had first requested disclosure from the district office and had only then approached the Entrusted Company in accordance with that guidance; and (iii) submitted, with supporting authority, the doctrinal point that Client A had merely exercised the rights of inspection and copying that Article 124 of the Urban Improvement Act presupposes for cooperative members, such that the conduct could not be characterized as acquiring personal information by deception or by other socially unacceptable means. On 6 May 2026, the Seoul Mapo Police Station issued a no-forwarding (no suspicion) decision in favor of Client A, holding that the conduct concerning the provision of the scanned written-resolution files did not satisfy the constituent elements of PIPA Article 71, item 1 or Article 70, item 2 (Seoul Mapo Police Station Case No. 2026-000807). The case is of practical significance in delineating the relationship between the inspection-and-copying rights of cooperative members under the Urban Improvement Act and the third-party-provision and acquisition rules under PIPA, and in managing criminal risk in information-disclosure disputes in improvement-project matters.