Enforcing jurisdiction
Finland · Geography does not establish applicable law.
Confirmed applicable legislation
Privacy topics

DPA case TSV/112/2022 (9079/152/22) – Complaint Upheld (Finland, 2025)

Complaint Upheld
DPA Tietosuojavaltuutetu11 November 2025Finland
final
Complaint Upheld

Privacy enforcement record

This record is classified outside cookie consent. Subject classification does not confirm an applicable law. It is not included in cookie statistics or the Risk Calculator.

A company failed to provide a user access to their personal data as requested, which is against data protection rules. The Finnish Data Protection Authority found that the company made it unnecessarily complicated for the user to access their information. This case underscores the importance of making it easy for users to access their own data.

What happened

A company did not provide a user access to their personal data despite multiple requests.

Who was affected

The individual who requested access to their personal data was affected by the company's actions.

What the authority found

The DPA determined that the company violated GDPR rules by not facilitating the user's right to access their data.

Why this matters

This case serves as a reminder for businesses to streamline their processes for data access requests. Companies must ensure they comply with data protection laws to avoid similar issues.

Recorded legal citations
Automatically processed
Art. 5(1)(c) GDPR
Art. 12(2) GDPR
Art. 12(6) GDPR
Art. 15(1) GDPR
Art. 15(3) GDPR
View original scraped data
Art. 5(1)(c) GDPR
Art. 12(2) GDPR
Art. 12(6) GDPR
Art. 15(1) GDPR
Art. 15(3) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

Source checks

Secondary-source text retrieved.

Automated check recorded — 18 October 2026.

No issues were reported by that automated check.

Retrieved text may be a secondary summary or an announcement. These automated statuses do not establish that the original decision was read or that the record received an independent legal review. How we check sources

Full Legal Summary
Detailed

On 13 October 2022, the data subject requested access to data concerning them held by Company A by email pursuant to Article 15(1). On 19 October 2022, Company A responded but it did not provide the requested information. Company A required the data subject to fill in a form on its website. On 31 October 2022, the data subject again requested access to the data by email. On 14 November 2022 the controller answered by again requiring the data subject to fill in the form on the website. According to the data subject, the form requested information such as their personal identification number. The controller argued that this is necessary in order to identify the data subject. The DPA found that the controller violated Article 15(1) and Article 15(3) GDPR by failing to implement the data subject’s right of access. It also held that the controller violated Article 12(2) and Article 12(6) GDPR by not facilitating the exercise of that right and by requesting more information than necessary. The DPA found that the controller failed to assess whether it could identify the data subject based on the information already provided and instead required routine collection of additional information. Therefore, this requirement did not facilitate the exercise of the right of access under Article 12(2). Under Article 12(6) GDPR, additional information may only be requested where there are reasonable doubts about the identity. The DPA considered that the controller failed to demonstrate such doubts. Hence, the personal identity number constituted unnecessary additional information and its request violated Article 12(6) GDPR. The DPA further held that the controller infringed the data minimisation principle under Article 5(1)(c). By requiring the personal identification number as part of a routine identification practice, although it did not previously process that data and could identify the data subject based on the information already provided, the controller requested more person

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for DPA case TSV/112/2022 (9079/152/22) in FI

This is the only recorded action for this entity in this jurisdiction.

Details

Decision Date

11 November 2025

Authority

DPA Tietosuojavaltuutetu

GDPRhub ID

gdprhub-9830

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. DPA case TSV/112/2022 (9079/152/22) - Finland (2025). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: