- Enforcing jurisdiction
- Belgium · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
DPA case 97/2026 – Complaint Upheld (Belgium, 2026)
Privacy enforcement record
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The Belgian Data Protection Authority upheld a complaint from a technician who couldn't access his work records. This is significant because it highlights the right of individuals to access their personal data held by employers.
What happened
The technician's request for access to his work records was not fulfilled by his employer.
Who was affected
The technician who worked for the company and requested access to his service sheets.
What the authority found
The authority ruled that the employer must comply with the technician's request for access to his records.
Why this matters
This case reinforces the importance of transparency and access rights for employees, reminding companies to have clear processes for handling access requests.
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Automated check recorded — 18 October 2026.
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The data subject was a technician employed by the controller. The controller used weekly handwritten service sheets as a system for recording working time. These sheets contained the technician’s working hours, journeys, services performed and the clients visited. On 10 May 2021, the data subject requested copies of their service sheets covering the previous five years in order to verify whether the hours they had reported corresponded to those recorded by the controller. The controller provided only the sheet concerning the week of 3 May 2021 to 9 May 2021 and subsequently proposed that the data subject arrange an appointment to consult the records at its premises. The data subject reiterated the request on 17 January 2022 and again in 2023, but never received the requested copies. On 27 July 2023, the data subject lodged a complaint with the Belgian DPA. The DPA issued the prima facie Decision 14/2025, where it ordered the controller to comply with the data subject’s access request and warned it of potential violations of Article 15(3) GDPR and Article 12(3) GDPR. The controller requested an examination on the merits. The controller argued that the data subject’s request had not clearly distinguished between the handwritten service sheets and a computer-generated statement. It further claimed that the request was excessive under Article 12(5) GDPR because the documents were stored by date rather than by employee in several dozen binders. Locating, copying and scanning the relevant records would therefore require considerable workload. For that reason, it had invited the data subject to inspect the binders in its premises and identify the relevant documents to be copied. The data subject maintained that their request had always been clear, that the computer-generated statement was incomplete and unintelligible and that the practical difficulties relied upon by the controller resulted from its own archiving practices. The DPA ruled that the data subject had made a
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 97/2026 in BE
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. DPA case 97/2026 - Belgium (2026). Retrieved from cookiefines.eu
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