BAYERISCHES LANDESAMT FÜR DATENSCHUTZAUFSICHT
Data Protection Authority of Bavaria for the Private Sector
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Our reference: LDA-1085.1-4732/20-F
Reference Sweden: DI-2021-2433
IMI draft decision: 597171
Controller:
On the basis of the draft decision of the Swedish Integritetsskyddsmyndigheten (SWE DPA) no. 597171,
the Data Protection Authority of Bavaria for the Private Sector (BayLDA) pursuant to Article 60(8) of the
GDPR issues the following
Final Decision:
The complaint is rejected.
Justification:
The complaint was received by the BayLDA on 21.01.2020 and was forwarded via IMI to the SWE DPA as
the lead data protection supervisory authority for the controller.
On 18.01.2024, the SWE DPA submitted the draft decision no. 597171 to the concerned supervisory au-
thorities with the following contents:
The Swedish Authority for Privacy Protection (IMY) has received a complaint as the lead supervisory
authority pursuant to Article 56 of the General Data Protection Regulation (GDPR). The handover has
been made from the supervisory authority of the country where you have lodged your complaint
(Germany) in accordance with the provisions of the GDPR on cooperation in cross-border processing.
IMY shall process complaints about incorrect processing of personal data and, where appropriate, in-
vestigate the subject matter of the complaint (Article 57(1)(f) of the GDPR).
The complaint shows, in essence, the following: In October 2019, you have requested that
delete your personal data and have received confirmation from a customer service officer by tele-
phone that your personal data will be deleted by November 2019. You do not believe that
has met your request for deletion because in January 2020 you received a letter about new unpaid
invoices from .
IMY considers that it is not apparent from the information in the complaint that your request for dele-
tion has not been met by . It is possible to use ’s services even after
one’s personal data has been previously deleted, in this case the data subject must again request to
have their personal data deleted. It is not apparent from the complaint that you have requested
to delete your personal data again. What you have stated does not give IMY any reason to
suspect a deficiency in relation to the provisions of the General Data Protection Regulation.
Against this background, the case is closed.
As the concerned supervisory authorities (including BayLDA) did not object to this draft decision, the
BayLDA hereby adopts this draft decision as final decision in accordance with Article 60(8) of the GDPR.
Ansbach, 21.02.2024