The case concerns the German credit reference agency CRIF Germany and it's data supplier Acxiom (an address trader). It's basically the same as the Austrian Case against CRIF Austria and AZ Direct, where the Austrian DPA already upheld noyb's complaint.
The interesting part is that the German DPAs already published an opinion that credit reference agency must ask for consent to process so-called "positive data" (i.e. data that are not connected to payment defaults) such as name, date of birth and addresses. CRIF Germany seems to wilfully ignore this and secretly obtains huge bulks of data from address publishers.
| Data | Podsumowanie |
|---|---|
| 07.08.2024 | change in DPA competent for CRIF BayLDA informed us that CRIF moved its seat to another state in Germany (Baden-Würtemberg). Therefore, the competent authority is now the LfDI. |
| 12.03.2024 | information from BayLDA BayLDA informs us that no appeal proceeding is ongoing. |
| 06.03.2024 | noyb asks the BayLDA if CRIF appealed the decision |
| 05.03.2024 | noyb statement to HDMI noyb statement in response to the controller submissions we received after getting access to the case file |
| 31.01.2024 | HBDI provides access to the case file HBDI provides access to the case file |
| 21.12.2023 | BayLDA upholds the complaint CRIF has violated the principle of purpose limitation and Art 15 GDPR. The BayLDA will also conduct ex officio investigations that go beyond the individual case. |
| 18.12.2023 | noyb writes BayLDA in light of recent CJEU case law re SCHUFA We ask them to take joined cases C-26/22 and C-64/22 and C-634/21 into consideration. |
| 16.10.2023 | Reply noyb on the questions of VG Wiesbaden |
| 06.10.2023 | |
| 04.10.2023 | Reply noyb on Acxioms submission |
| 13.09.2023 | Acxiom sends submission against data subject being heard on access to case files |
| 31.07.2023 | noyb provides BayLDA with recent case law on the matter |
| 24.07.2023 | noyb requests to be heard on acces to case files Acxiom is trying to get an court injunction which would prohibit the HBDI from giving us access to the case files. We filed an application to be included in this court case to avoid an unfair procedure where the complainant is excluded. |
| 12.07.2023 | HBDI informs us that we will not get access to the case file but the controller will |
| 11.07.2023 | BayLDA says they need to ask CRIF further questions They also will inform (not hear!) us prior to issuing a decision. |
| 17.05.2023 | HBDI says that the will need to hear Acxiom on our request to get the case files |
| 16.05.2023 | Update by BayLDA We will be informed (not heard apparently) on the DPAs conclusions before they finally decide. |
| 11.05.2023 | noyb reiterates request for access to case files to HBDI |
| 11.05.2023 | noyb requests to be informed what CRIF argued |
| 10.05.2023 | Update by BayLDA CRIF has brought completely new arguments which need to be assessed. |
| 24.03.2023 | noyb provides BayLDA with DSB decision re CRIF AT |
| 23.03.2023 | Request for access to files to HBDI |
| 22.03.2023 | Update 2 by HBDI |
| 09.02.2023 | Further request for update to both DPAs |
| 26.09.2022 | Update HBDI They will get back to us, when Acxiom has provided their statement. |
| 16.08.2022 | BayLDA asks to be provided with DSB decsion re CRIF AT once passed |
| 10.08.2022 | noyb informs both DPAs about DSB decision re AZ Direct |
| 22.07.2022 | Request for update to both DPAs |
| 08.03.2022 | Reply to BayLDA |
| 07.03.2022 | Update 3 by BayLDA |
| 28.01.2022 | Update 2 by BayLDA |
| 02.12.2021 | Update 1 by BayLDA |
| 15.11.2021 | HBDI confirms receipt re Acxiom |
| 20.10.2021 | BayLDA confirms receipt re CRIF |
| 18.10.2021 | Complaint |