- Enforcing jurisdiction
- Finland · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
DPA case TSV/88/2022 – Violation Found (Finland, 2024)
Privacy enforcement record
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A Finnish authority found that a media company made it too difficult for a person to access their personal data. This is important because it shows that companies must make it easy for users to exercise their rights regarding their data.
What happened
The media company required a signed form and in-person identification to process a person's request for access to their data.
Who was affected
A person who requested access to their personal data held by the media company.
What the authority found
The authority ruled that the company's method for verifying identity was excessive and violated data protection principles.
Why this matters
This case serves as a reminder for companies to simplify the process for individuals seeking access to their data, ensuring it aligns with data protection laws.
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The Finnish DPA was notified that a media company (the controller) had requested the data subject to deliver a signed form to the controller's premises in order to exercise the right of access. The data subject made an access request by email but did not provide any other information to confirm their identity. Therefore, the controller did not provide access to the personal data. The DPA had asked the controller to explain why it had refused to comply with the data subject's request and how it had facilitated the exercise of data subject rights. In response to the request, the controller clarified that it could not comply with the data subject's request because the data subject had not provided additional information to confirm their identity. The controller stated that the data subject must identify themselves by means of a form containing the data subject's name, personal identification number, address, telephone number and email address. The controller also noted that the form must be signed and delivered in person to the controller's premises, where the data subject must identify themselves with a government-issued ID. On the basis of the information provided by the controller, the DPA considered that the controller's method of identifying the data subject was not based on a case-by-case assessment. Therefore, contrary to the principle of data minimisation, the controller had processed a wider range of personal data than necessary to identify the data subject, in particular since the controller had not provided reasons why it was not possible to identify the data subject. The DPA emphasised that it was disproportionate to require data subjects to personally deliver a signed form to the controller's premises and to identify themselves with an ID, especially for data subjects who do not live close to the controller's premises. On the basis of the information gathered, the DPA held that the controller had violated Article 5(1)(c) GDPR, Article 12(2) GDPR and Arti
Outcome
Violation Found
The DPA found a violation but did not impose a fine.
Related Enforcement Actions (0)
No other enforcement actions found for DPA case TSV/88/2022 in FI
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. DPA case TSV/88/2022 - Finland (2024). Retrieved from cookiefines.eu
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