AKI - 2.1.-1/19/126

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AKI - 2.1.-1/19/126
Authority: AKI (Estonia)
Jurisdiction: Estonia
Relevant Law: Article 12(1) GDPR

Article 13(4) GDPR

Article 14(5)(a) GDPR

Article 15 GDPR

Type: Complaint
Outcome: Rejected
Decided: 1.11.2019
Published: 13.11.2019
Fine: None
Parties: Luminor Pank AS Vs. anonymous
National Case Number: 2.1.-1/19/126
European Case Law Identifier: n/a
Appeal: n/a
Original Language:


Original Source: AKI (in EE)

The AKI re-examined complaint about financial service provider’s incomplete response to data subject’s access request after appeal.

English Summary


The appellant complained that the company, in response to his access request, provided an incomplete dataset in English.


Could Article 15 GDPR be exercised although the personal are expected to be already possessed by the data subject?


The DPA found that much of the data that the complainant found as missing is data that the complainant is expected to possess. So, it concluded that the company is not obliged to provide data that the data subject already possesses under Articles 13(4) and 14(5)(a) GDPR. Thus, the DPA found that the company has adequately fulfilled the obligation to inform the data subject of the data processing as required by Articles 13-15 GDPR. Finally, the DPA pointed out that the complainant had indicated in its customer profile a language preference to use English, which justifies the data export in English (Article 12(1) GDPR).


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English Machine Translation of the Decision

The decision below is a machine translation of the original. Please refer to the German original for more details.

To be completed ...