Hi Harald,
I'm not expert in legal stuff, but I think the European regulations (at least in Spain because I needed to learn this in order to host web sites with any kind of registration or list of people and comply with the law), there is no difference in publishing it before, during or after. Just can't be published w/o the consent of the participant.
I think you are right, however that does not mean that a 'to use this service you must agree to having your information published'-rule is incompatible with EU privacy legislation. I think Haralds proposed fix is probably fine.
MVH leifj
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