DR (Denmark's Radio) – Violation Found (Denmark, 2025)

DR (Denmark’s Radio, the controller) is Denmark’s public service broadcaster. In autumn 2024, the controller required users (the data subjects) to log in to access streaming content on DRTV, an internet streaming television service, which had previously been freely accessible.  After receiving a number of complaints, the Danish DPA started an investigation whether controller's processing of personal data in this regard was, inter alia, in accordance with GDPR. When creating a user profile to log in to DRTV, data subjects must provide several pieces of information, including their email, IP address, a name, and details about which programs the profile accesses. According to the controller, by the end of August 2025, 3,400,000 data subjects were registered on DRTV. Regarding the mandatory nature of the login, the controller argued that, as part of its public service obligation, it must provide a modern, online streaming service that offers a personalized and coherent user experience. A streaming service without login and associated interactive features would not meet contemporary standards and therefore would fail to fulfill its public service responsibilities. The DPA found lawful that the controller offered a streaming service that mandatory requires login and collects personal data, since collecting and processing personal data for DRTV login was necessary to fulfill their public service obligations under Article 6(1)(e) GDPR The aim of the controller, to provide a modern, network-based public service streaming platform that meets data subject ‘s digital expectations is a relevant and lawful public interest. However , the DPA held that the collection of data in the form of name, until 5 September 2025 , was contrary to Article 5(1)(c) GDPR on the principle of data minimization, since GDPR requires that personal data be limited to what is necessary for the stated purpose. The controller asked the data subjects to enter their name when creating a profile even tho