Enforcement · Hungarian National Authority for Data Protection and the Freedom of Information (NAIH) 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.

Claim management company: Insufficient legal basis for data processing

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).

€2,850 Fine
Claim management company
HUNGARY
Art. 5 GDPR Art. 6 GDPR
Legitimate Interest Controllers Consent Personal Data Processing
Jun 3, 2019 Source naih.hu

Full text

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.

Industry: Finance, Insurance and Consulting

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