C044 CRIF Bürgel (Germany)

Credit Scoring
Controller
CRIF Bürgel (Germany)
Case status
Pending (3 - 4 years)
Filed: (3 years 2 months ago)

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.

Protocol
Data Podsumowanie
04.12.2024
Request for information about status of the case

After phone call with the DPA email to obtain more information

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