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

Oy BMW Suomi Ab – Dismissed (Finland, 2022)

Dismissed
DPA Tietosuojavaltuutetu8 June 2022Finland
final
Dismissed

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.

The Finnish DPA dismissed a complaint from a customer who wanted access to a used vehicle's maintenance history. The DPA found that this information did not qualify as personal data for the new owner. This case matters because it clarifies the limits of personal data access rights under GDPR. Businesses should understand what constitutes personal data to avoid confusion.

What happened

A customer's request for access to a used vehicle's maintenance history was dismissed.

Who was affected

The new owner of the used BMW vehicle was affected by the decision.

What the authority found

The Finnish DPA determined that the vehicle's service history did not qualify as personal data of the new owner under GDPR.

Why this matters

This decision highlights the nuances of personal data rights. Companies should be clear about what information can be shared and under what circumstances.

Recorded legal citations
Automatically processed
Art. 15 GDPR
Art. 4(1) GDPR
View original scraped data
Art. 4(1) GDPR
Art. 15(GDPR)

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

Source checks

Linked-source text retrieved.

Automated check recorded — 21 March 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

The data subject purchased a used BMW vehicle and discovered defects requiring repair. Assuming that the defects were known to the BMW dealership (controller), the data subject requested information about the maintenance and repair history for the vehicle's entire lifecycle. However, the controller declined to comply with the request. When assessing the controller's response, the Finnish DPA checked whether the vehicle's service history was personal data within the meaning of Article 4(1) GDPR. It also analysed whether it would be the personal data of the new owner, giving them the right to access this information under Article 15 GDPR. The DPA held that the vehicle maintenance and repair history might directly or indirectly describe the activities of the vehicle's owner or holder. For example, it may tell how the owner used the vehicle, including its running distance and the owner's driving style. In addition, although the service history usually does not indicate the owner's name, the person can be identified when combining information from other sources, such as a public transportation registry. Hence, the DPA considered that the vehicle service history information relates to an identifiable natural person and thus is personal data under Article 4(1) GDPR. Nevertheless, this information may also include non-personal data to which the GDPR does not apply. Finally, the vehicle service history information cannot be considered the new owner's personal data due to the minimal effect this information has on them. Consequently, the DPA held that the new vehicle owner does not have the right to access this information under Article 15 GDPR when the information relates to another person. However, under other grounds, such as legitimate interest, the controller could still disclose this information to new buyers if it wished to.

Outcome

Dismissed

The complaint or investigation was dismissed.

Related Enforcement Actions (0)

No other enforcement actions found for Oy BMW Suomi Ab in FI

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

Details

Decision Date

8 June 2022

Authority

DPA Tietosuojavaltuutetu

GDPRhub ID

gdprhub-4983

About this data

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

Cite as: Cookie Fines. Oy BMW Suomi Ab - Finland (2022). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: