Claim management company
Insufficient legal basis for data processing
결정 날짜
2019년 6월 3일
권한
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)
HU
섹터
Finance, Insurance and Consulting
국가
HU
법률
GDPR상태
FINAL설명
The complainants stated during the case that they concluded a credit agreement with the bank, which sold its claim against the complainants and transferred their respective data to a third-party company (controller). NAIH determined in the case that the controller can neither rely on the consent of the data subjects nor the performance of the credit contract as the legal basis of the data processing, since the data subjects concluded such contract with the bank, not with the controller. The appropriate legal basis for processing could have been the legitimate interest of the controller.