Notice: This document is an unofficial translation of the Swedish Authority for
Privacy Protection’s decision. Only the Swedish version is authentic. 1(8)
COMPLAINANT
See appendix
CONTROLLER
Klarna Bank AB
Swedish ref.:
IMY-2025-9254 Final decision under the General Data
Protection Regulation – Klarna Bank
IMI case register:
134712 AB
Date:
2025-11-04
Decision of the Swedish Authority for Privacy
Protection
The Swedish Authority for Privacy Protection finds that Klarna Bank AB (556737-0431)
in its handling of the complainant’s request for access made on 2 September 2019 has
processed personal data in breach of:
• Article 12(6) GDPR1 by requesting more data than is necessary to identify the
complainant
• Article 12(2) of the GDPR by not facilitating the exercise of the complainant’s
right.
The Swedish Authority for Privacy Protection issues a reprimand to Klarna Bank AB
pursuant to Article 58(2)(b) of the GDPR for the infringements of Articles 12(6) and
12(2) of the GDPR.
Presentation of the supervisory case
Background and handling of the case
IMY has initiated supervision against Klarna Bank AB (Klarna or the company) in case
IMY-2022-7128 due to several complaints against the company, including the
complaint in the present case. IMY has subsequently decided to continue processing
the present complaint in a separate case with a new case number, IMY-2025-9254. As
a consequence, previous communication in the current case has been conducted
through letters with case number IMY-2022-7128.
Postal address:
The complaint in the case has been submitted to IMY, as lead supervisory authority
Box 8114
104 20 Stockholm under Article 56 GDPR. The transfer has taken place from the supervisory authority of
Sweden the country where the complainant has lodged the complaint (Germany) in accordance
Website: with the provisions of the Regulation on cooperation in cross-border processing.
www.imy.se
E-mail:
[email protected] 1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of
Telephone: natural persons with regard to the processing of personal data and on the free movement of such data, and repealing
+46 (8) 657 61 00 Directive 95/46/EC (General Data Protection Regulation).
Page 1 of 8
Swedish Authority Our ref.: IMY-2025-9254 2(8)
for Privacy Protection Date: 2025-11-04
The proceedings before IMY were conducted by exchange of letters. IMY has made
use of the cooperation and consistency mechanisms provided for in Chapter VII of the
GDPR. Relevant supervisory authorities have been the data protection authorities of
Austria, Hungary, Denmark, Germany, Norway, Finland, Italy, the Netherlands,
Poland, Ireland, France, Estonia and Spain.
Statement by the complainant
The complainant states, in essence, as follows. The complainant has received a
payment reminder for a purchase he allegedly made. He has objected to payment for
the alleged purchase. As a result, the applicant suspected that his personal data had
been misused and therefore requested a right of access on 2 September 2019. Klarna
sent a reply to the complainant on 26 September 2019 asking the complainant to
provide further information. The information requested by Klarna has already been
available to the company. In any event, the company cannot be regarded as having
had the right to request further information. Klarna’s reply to the complainant delays
and complicates the exercise of the right of access.
Statement by Klarna
In summary, Klarna has stated the following about the issues covered by the
supervision in this case.
Klarna is the data controller for the processing that is the subject of the complaint.
Klarna received a request for access from the complainant by post on 2 September
2019. Klarna has handled the request by starting the identification process on 26
September 2019. The complainant did not reply and the request could not therefore be
complied with.
Has Klarna had reason to doubt the identity of the complainant?
Klarna has stated that in June 2017 the company was granted a banking license by
the Swedish Financial Supervisory Authority. This means, among other things, that the
company is obliged to maintain banking secrecy in accordance with Chapter 1, Section
10 of the Banking and Financing Business Act (2004:297) and that Klarna must
therefore not unlawfully disclose individuals’ relationship with Klarna as a credit
institution. In addition, Klarna processes information that many customers perceive as
sensitive, such as credit decisions, payment history and information according to the
anti-money laundering regulations. Klarna therefore needs to ensure that information is
not disclosed to unauthorised persons and that the identity of customers is not
revealed. Therefore, in addition to the provisions of data protection law, the
requirement of banking secrecy must also be taken into account when identifying data
subjects in the context of access or erasure requests. Furthermore, it should be noted
that financial institutions, such as, inter alia, banks, are particularly vulnerable to fraud
attempts of various kinds. One example is attempts to obtain personal data from third
parties that enable identity theft. Providing personal data to an unauthorized third party
would not only enable fraud at the expense of the data subject and Klarna, but
potentially also on the data subjects of online merchants who have used one of
Klarna's payment methods. Consequently, Klarna must ensure that no personal data is
exposed to unauthorized persons and, in case of doubt, ask for additional data points
for identification.
Klarna continuously develops its identity verification processes to ensure that
unauthorized persons cannot access customers' personal data.
Page 2 of 8
Swedish Authority Our ref.: IMY-2025-9254 3(8)
for Privacy Protection Date: 2025-11-04
Klarna had reason to doubt the identity of the complainant, since the complainant only
provided two of the three necessary data points to be considered identified according
to the current routine. For this reason, Klarna has not been able to fulfil the request. In
addition, the e-mail address provided was not the one with which the applicant made a
purchase via Klarna. As a result, Klarna is unable to identify the complainant in
accordance with the company’s procedures. For this reason, Klarna has not been able
to comply with the request.
What information has Klarna required to handle the request?
Klarna states that the complainant was asked to provide the following information:
• Name
• Date of birth
• E-mail address
• Invoice number
• Name of a shop from which the complainant made a purchase.
What information was collected when the customer relationship was established
and what is new?
For identification purposes, Klarna only collects data corresponding to the data already
collected.
Why was the information necessary to confirm the identity of the complainant?
Klarna's identification routine has always been based on the premise that a customer's
identity can be verified by the customer providing a number of different data points that
only the customer should know about, and to prevent unauthorised persons from
guessing the information required for identification. In order to simplify for customers,
Klarna states within the identificationprocess the points that in different combinations
can be used to verify a customer's identity. Since customers can remember different
data and have used payment methods that require different data, Klarna has provided
the complete list of data points. However, not all information from the list is needed in
each individual case. Instead, different combinations of these points have been
sufficient to identify the customer, depending on when in time and in which country the
request was made. In cases where a customer service employee requested additional
data points even though a customer had already submitted enough information to be
identified, the cases have been handled incorrectly. An important exception is cases
where Klarna has not been able to find the customer because the information entered
by a customer has not matched the information in Klarna's system. In such cases, it
has been considered necessary, for example, to request an alternative e-mail address.
In the present complaint, according to the identification procedure then in force for
Germany, Austria, Belgium and the Netherlands, Klarna has not been able to carry out
a secure identification of the complainant and has therefore requested additional
information to ensure that the complainant’s personal data does not fall into the wrong
hands. In doing so, Klarna has indicated all the additional data points that count as
possible data points, but different combinations of those data points have been
possible for the secure identification of the complainant.
Applicable provisions, etc.
Pursuant to Article 12(2) of the GDPR, the controller shall facilitate the exercise of the
data subject’s rights in accordance with Articles 15 to 22.
Page 3 of 8
Swedish Authority Our ref.: IMY-2025-9254 4(8)
for Privacy Protection Date: 2025-11-04
Article 12(6) of the GDPR states that, without prejudice to Article 11 of the GDPR,
where the controller has reasonable doubts concerning the identity of the natural
person making the request reffered to in Articles 15 to 21, the controller may request
the provision of additional information necessary to confirm the identity of the data
subject.
The European Data Protection Board (EDPB) Guidelines 01/2022 on the right of
access2 state the following.
In cases where the controller requests or is provided by the data subject with
additional information necessary to confirm the identity of the data subject, the
controller shall, each time, assess what information will allow it to confirm the
data subject’s identity and possibly ask additional questions to the requesting
person or request the data subject to present some additional identification
elements, if it is proportionate.3
As indicated above, if the controller has reasonable grounds for doubting the
identity of the requesting person, it may request additional information to
confirm the data subject’s identity. However, the controller must at the same
time ensure that it does not collect more personal data than is necessary to
enable authentication of the requesting person. Therefore, the controller shall
carry out a proportionality assessment, which must take into account the type of
personal data being processed (e.g. special categories of data or not), the
nature of the request, the context within which the request is being made, as
well as any damage that could result from improper disclosure. When assessing
proportionality, it should be remembered to avoid excessive data collection
while ensuring an adequate level of processing security.4
The assessment by IMY
Has Klarna acted in accordance with Article 12(6) of the GDPR when Klarna
requested additional data from the complainant?
Has Klarna had reasonable grounds to doubt the identity of the complainant?
It is only where the controller has reasonable doubts as to the identity of the requester
that additional information to confirm the identity may be requested. What constitutes
‘reasonable grounds’ in Article 12(6) of the GDPR should be assessed in the light of
the circumstances of the individual case. The assessment of whether there are
reasonable grounds to doubt the identity of the requester in an individual case is
normally made in the light of the information provided in the context of the request.
This is particularly true in situations where the controller does not have detailed
knowledge of that person. However, the need for an individual assessment does not
preclude the establishment of procedures by which the controller normally verifies the
identity of the data subject.
The requirements that can be placed on the information should typically be higher the
more sensitive the processing of the personal data is. In other words, one type of
2 European Data Protection Board (EDPB) Guidelines on the right of access – Guidelines 01/2022 on data subject
rights – Right of access, version 2.0 (finally adopted on 28 March 2023) (EDPB Guidelines 01/2022).
3
EDPB Guidelines 01/2022, paragraph 67
4 EDPB Guidelines 01/2022, paragraph 70.
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Swedish Authority Our ref.: IMY-2025-9254 5(8)
for Privacy Protection Date: 2025-11-04
information for identification may be sufficient for identification in the case of one
processing operation but may cast doubt in the case of another.
In the letter sent by the complainant to Klarna on 2 September 2019, it appears that
the complainant provided the following information in the context of its request:
• First and last name
• Postal address
• E-mail address
• Phone number
• Invoice number.
Klarna states, inter alia, that the email address provided by the applicant was not the
one with which the applicant made the purchase via Klarna. In addition, Klarna states
that the requirement of banking secrecy, which it is required to maintain, must be taken
into account when identifying data subjects in connection with requests for access or
deletion. In addition, Klarna processes information that many customers perceive as
sensitive and the company thus needs to ensure that information is not disclosed to
unauthorized persons and that the identity of customers is not disclosed. Financial
institutions are particularly vulnerable to fraud attempts of various kinds and Klarna
must ensure that no personal data is exposed to unauthorised persons and, if in doubt,
ask for additional data points for identification.
IMY notes that the purpose of the obligation to ensure the identity of the person
making the request is, inter alia, to protect data subjects against the erroneous making
of requests in their name by someone else, which may lead to negative consequences
for data subjects. In the light of Klarna’s submissions, in particular as regards the
nature of the personal data processed by Klarna, and in the light of the information
provided by the complainant in its request for access, IMY considers that there is no
reason to doubt that Klarna had reasonable grounds to doubt the complainant’s
identity.
Has the information requested by Klarna been necessary to confirm the identity of the
complainant?
The General Data Protection Regulation does not explicitly regulate which data may
be requested or how the additional information is to be collected. However, the
principle of data minimisation laid down in Article 5(1)(c) of the GDPR is central in this
regard. Even if the controller has reasonable doubts about the identity of the data
subject, the controller shall not collect more personal data than is necessary to enable
the identification of the data subject. To routinely require data for identification without
regard to whether the data are necessary in the manner described in Article 12(6) of
the GDPR is contrary to that provision. The controller must carry out a proportionality
assessment and be able to justify the verification method used. The proportionality
assessment must be carried out in order to determine what is appropriate in the light of
the Regulation’s requirements relating, inter alia, to security, but also in the light of the
requirement laid down in Article 12(2) of the GDPR, according to which the controller is
to facilitate the exercise of the data subject’s rights. In order to avoid excessive data
collection, a request for additional information must be proportionate to the type of data
being processed and the harm that may result from the disclosure of data to the wrong
person.
In summary, Klarna has stated that data subjects can identify themselves through
different combinations of a number of data points established in Klarna's routine. In the
Page 5 of 8
Swedish Authority Our ref.: IMY-2025-9254 6(8)
for Privacy Protection Date: 2025-11-04
identification process, all of these possible data points are requested, but not all of
them are necessary for the identification of the data subject.
It follows, inter alia, from the EDPB Guidelines on the right of access that, in the
proportionality assessment, the controller must take into account the type of personal
data processed (e.g. special categories of data or not), the nature of the request, the
context in which the request is made and any damage that may result from undue
disclosure.5
As regards the information requested by Klarna from the complainant, IMY notes the
following. In view of the fact that Klarna carries out banking activities, the disclosure of
personal data to an unauthorised person could have serious consequences for the
complainant. The identification requirements must therefore be set relatively high.
Klarna also only requests information that corresponds to information that the
company already processes about the complainant.
However, according to Klarna itself, not all of the additional information requested was
necessary to identify the complainant. As mentioned above, the controller shall carry
out a case-by-case assessment and shall not request more personal data than
necessary to identify the requesting data subject. It does not appear that Klarna made
such an assessment in the complainant’s case. To routinely require a large number of
data for identification in the manner that has taken place without regard to whether the
data are necessary in the manner described in Article 12(6) of the GDPR is contrary to
the provision in question.
In view of the fact that more data than was necessary to identify the complainant has
been requested, IMY considers that Klarna has processed the complainant’s personal
data in breach of Article 12(6) of the GDPR.
Has Klarna pursuant to Article 12(2) of the GDPR facilitated the exercise of the
complainant’s right of access?
Pursuant to Article 12(2) of the GDPR, the controller shall facilitate the exercise of the
data subject’s rights in accordance with Articles 15 to 22.
As stated above, IMY considered that not all the information requested by Klarna was
necessary to identify the complainant. In particular, Klarna requested information that
was already apparent from the complainant’s request for access, rather than informing
him that it needed an alternative email address in order to verify his identity. Klarna’s
request also meant that the complainant had to carry out investigations in order to find
several information concerning, inter alia, a purchase which the complainant disputes
that he has made. Against that background, IMY considers that the verification method
was burdensome for the appellant in such a way as to make it more difficult to exercise
the right of access.
Against this background, IMY considers that the verification method was too
burdensome for the complainant in such a way that it complicated the exercise of the
right of access.
5 EDPB Guidelines 01/2022, paragraph 70.
Page 6 of 8
Swedish Authority Our ref.: IMY-2025-9254 7(8)
for Privacy Protection Date: 2025-11-04
IMY therefore concludes that Klarna has not facilitated the exercise of the data
subject’s right in the manner required by Article 12(2) of the GDPR. Klarna has thus
processed the complainant’s personal data in breach of Article 12(2) of the GDPR.
Choice of corrective measure
It follows from Article 58(2) and Article 83(2) of the GDPR that the IMY has the power
to impose administrative fines in accordance with Article 83. Depending on the
circumstances of the case, administrative fines shall be imposed in addition to or
instead of the other measures referred to in Article 58(2), such as injunctions and
prohibitions. Furthermore, it is clear from Article 83(2) which factors must be taken into
account when deciding on an administrative fine and when determining the amount of
the fine. In the case of a minor infringement, as set out in recital 148, instead of
imposing a fine, IMY may issue a reprimand pursuant to Article 58(2)(b). Account shall
be taken of aggravating and mitigating circumstances of the case, such as the nature,
gravity and duration of the infringement and relevant previous infringements.
IMY notes the following relevant facts. IMY has found that Klarna has requested more
information than is necessary to identify the complainant. However, the data requested
by Klarna did not consist of sensitive, particularly protective or otherwise privacy-
sensitive data and only covered such data that Klarna already processes in the context
of its customer relationship with the complainant. IMY also found that Klarna had not
facilitated the exercise of the complainant’s right of access.
In an overall assessment of the circumstances of the present case, IMY considers that
Klarna should be given a reprimand for the infringements found.
This decision has been taken by the Legal Counsel after presentation
by legal advisor .
Appendix
The complainant’s personal data
Copy to
Data Protection Officer
Page 7 of 8
Swedish Authority Our ref.: IMY-2025-9254 8(8)
for Privacy Protection Date: 2025-11-04
How to appeal
If you wish to appeal the decision, you should write to IMY. Indicate in your letter the
decision you wish to appeal and the amendment you are requesting. The appeal must
be received by IMY within three weeks of the date on which you received the decision.
However, if you are a party representing the public, the appeal must be received within
three weeks of the date of notification of the decision. If the appeal has been received
in due time, IMY will forward it to the Administrative Court in Stockholm for
consideration.
You can e-mail the appeal to IMY if it does not contain any privacy-sensitive personal
data or information that may be covered by confidentiality. The contact details of the
authority can be found on the first page of the decision.
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