Suomen Asiakastieto Oy – Complaint Upheld (Finland, 2021)

Complaint Upheld
DPA Tietosuojavaltuutetu9 November 2021Finland
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Complaint Upheld

General GDPR enforcement action

This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.

Suomen Asiakastieto Oy, a Finnish credit information company, registered inaccurate data about people due to errors from 2011 to 2017. The Finnish DPA found that the company processed this data without a legal basis, violating GDPR rules. This decision emphasizes the need for companies to ensure data accuracy and have a valid legal basis for processing.

What happened

Suomen Asiakastieto Oy registered inaccurate credit data due to errors from external sources, without a legal basis.

Who was affected

Individuals whose credit information was inaccurately recorded in the company's register.

What the authority found

The Finnish DPA found that the company processed personal data without a valid legal basis, violating GDPR.

Why this matters

This case underscores the need for companies to verify the accuracy of data from external sources and ensure they have a legal basis for processing. It serves as a reminder to maintain data integrity and compliance with GDPR.

GDPR Articles Cited

Art. 5(1)(a) GDPR
Art. 83 GDPR
Art. 25(1) GDPR
Art. 58(2)(b) GDPR
Art. 58(2)(d) GDPR

National Law Articles

Article 6(1) Credit Information Act (527/2007)
Full Legal Summary
Detailed

Controller is Suomen Asiakastieto Oy, a company that keeps a credit information register. This register gives an overview of the creditworthiness of debtors, whose debts are shown in the register. Suomen Asiakastieto Oy receives information from the Legal Register Centre regarding court cases in which a debtor challenges a payment obligation. [https://gdprhub.eu/index.php%3Ftitle=Tietosuojavaltuutetun_toimisto_(Finland)_-_8211/161/19 Because the Courts and the Legal Register Centre made errors between 2011 and 2017, this information, turned out to be inaccurate and transferred without a legal basis, because it did not fulfil the obligations of Article 6(1) of the (Finnish) Credit Information Act]. Since the controller relied on the information provided by the Legal Register Centre, they also registered inaccurate personal data without a legal basis. A data subject who was registered in controller's credit register because of four cases, requested the DPA to order controller to delete their personal data from the controller’s credit information register, because it was processed without a legal basis and the controller did not provide clear criteria on which they determined the debtor's creditworthiness. The controller, however, argued that they carefully assessed each outcome of court cases to determine the creditworthiness of the debtor, that they had a legal basis to process this information (Article 6(1) Credit Information Act), and that they could not establish fixed criteria of this assessment, since this is “to some extend a matter of human reasoning and consideration” and must therefore be done on a case-by-case basis. First, the DPA noted that, although the issues occurred between 2011 and 2017, the issues had continued since the GDPR entered into force, and therefore, the GDPR applied to this case. Second, the DPA stated that that in each of the four instances, the entries should not have been registered, because these conditions laid down in Article 6(

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Details

Decision Date

9 November 2021

Authority

DPA Tietosuojavaltuutetu

GDPRhub ID

gdprhub-4513

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Suomen Asiakastieto Oy - Finland (2021). Retrieved from cookiefines.eu

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