Enforcement · Bulgarian Commission for Personal Data Protection (KZLD) EN LLM context A cited markdown file you can paste into your AI assistant (ChatGPT, Claude, a RAG or project knowledge base) to ground it in this document. Contains: this document’s text, its sections with their topics, and the full text of every law provision it applies. Everything links back to its source on overview.legal — legal information, not advice.

Bank: Insufficient legal basis for data processing

A fine of 1000 BGN (or roughly 500 EUR) was imposed on a bank for calling a client for the unresolved bills of his neighbor.

€500 Fine
Bank
BULGARIA
Art. 5 GDPR Art. 6 GDPR
Personal Data Consent Processing Right to be Forgotten Insurance
Dec 4, 2018 Source gdprtoolkit.eu

Full text

A fine of 1000 BGN (or roughly 500 EUR) was imposed on a bank for calling a client for the unresolved bills of his neighbor. This provoked the client to evoke his right to be forgotten. After not receiving any answer from the bank he filed another motion, for which the bank did take action in the statutory period. Nonetheless, the client filed a complaint to KZLD. The infringement for which the bank was fined was for the processing of the client’s personal data was not linked to his consumer credit agreement. Since the purpose for which the data were processed was different from that communicated at the time of conclusion of the contract, the bank had, in the point of view of KZLD, to request additional consent from its client.

Industry: Finance, Insurance and Consulting

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