Notice: This document is an unofficial translation of the Swedish Authority for
Privacy Protection’s final decision. Only the Swedish version is authentic. 1(9)
COMPLAINANT
See appendix
CONTROLLER
Klarna Bank AB
Swedish ref.:
IMY-2025-9256 Final decision under the General Data
German ref: Protection Regulation – Klarna Bank
521.14792/631.441
IMI case register:
AB
CR134712
Date:
2025-11-10
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 6 June 2021 has
processed the complainant’s personal data in breach of:
• Article 12(6) of the 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.
Postal address:
Box 8114
104 20 Stockholm
Sweden
Website:
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).
Swedish Authority Our ref.: IMY-2025-9256 2(9)
for Privacy Protection Date: 2025-11-10
Presentation of the supervisory case
Background and demarcation
The Swedish Authority for Privacy Protection (IMY) has initiated supervision in case
with Swedish reference number IMY-2022-7128 to investigate 28 complaints2 against
Klarna Bank AB (Klarna). Subsequently, IMY has decided that the further investigation
of each complaint will take place in separate cases.
IMY’s investigation of the complaint in the present case has been limited to the
questions whether Klarna has acted in accordance with Article 12(6) of the GDPR
when Klarna requested data to identify the complainant and facilitated the
complainant’s exercise of its right of access in accordance with Article 12(2) of the
GDPR. The investigation in the case concerns Klarna’s handling of the complainant’s
request for access made on 6 June 2021. IMY will therefore not take a position on
whether Klarna's current, general routines for handling requests are compatible with
the General Data Protection Regulation.
The complaint in the case has been submitted to IMY, as lead supervisory authority
under Article 56 GDPR. The transfer has taken place from the supervisory authority of
the country where the complainant has lodged the complaint (Germany) in accordance
with the provisions of the Regulation on cooperation in cross-border processing.
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.
On 6 June 2021, the complainant requested access to his personal data pursuant to
Article 15 of the GDPR. Klarna has required more personal data than necessary
handle his request. He has not been able to provide Klarna with the requested data
because he orders something every day and does not know what payments were
made via Klarna. He is also not willing to allow Klarna, a company that has had a data
breach, receive additional information about him not necessary to handle his request.
The complainant has in the context of his request made by letter given Klarna his first-
and last name and his postal address.
Klarna has responded to the complainant and requested the following information in
order to identify him:
• First- and last name
• Date of birth
• E-mail address used for a purchase with Klarna
• Klarna invoice number for one of the orders
2 IMY initiated supervision in response to 29 complaints but on 23 September 2023 the complainant withdrew
complaint 14 (DI-2021-5908).
Swedish Authority Our ref.: IMY-2025-9256 3(9)
for Privacy Protection Date: 2025-11-10
• Name of a merchant the complainant placed an order with
• Exact invoice amount for one of the orders
• Billing address (if the product Billpay was used).
Klarna has further requested the complainant’s old and new postal addresses, if he
has moved within the last 24 months for verification purposes. Klarna has also
requested a telephone number to send a password to the complainant so that he can
open a copy of the personal data.
Finally, Klarna also requested transaction-ID and IBAN if the complainant has used
Klarna Open Banking through a third-party provider and wants access to the personal
data stored by it.
Statement by Klarna
In summary, Klarna has stated the following about the issues covered by the
supervision in this case.
Klarna received the complainant’s request for access by mail on 10 June 2021 and
initiated the identification process on 18 June 2021. The complainant provided the
requested information by e-mail on 19 July 2021. Klarna requested the same
information again by mistake on 28 July 2021. On 28 December 2021, a copy of the
complainant’s personal data was sent by letter.
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.
At the time of the request, Klarna had reason to doubt the identity of the complainant,
since the complainant only provided his name and, as may be understood, postal
address, i.e. two of the necessary data points to be considered identified according to
the current routine. For this reason, Klarna has not been able to fulfil the request
Swedish Authority Our ref.: IMY-2025-9256 4(9)
for Privacy Protection Date: 2025-11-10
before the complainant has provided the other required data points which have
enabled an identification and subsequently Klarna to provide him with a copy of his
personal data in accordance with his 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 merchant the complainant placed an order with
• Invoice amount for the purchase.
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 identification process 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.
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.
What information was collected when the customer relationship was established
and what is new?
Klarna has not been able to identify data about the complainant’s first purchase.
However, for identification purposes, Klarna only collects data corresponding to the
data already collected.
Motivation of the decision
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.
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 referred to in Articles 15 to 21, the controller may request
Swedish Authority Our ref.: IMY-2025-9256 5(9)
for Privacy Protection Date: 2025-11-10
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
access3 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.4
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.5
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
information for identification may be sufficient for identification in the case of one
processing operation but may cast doubt in the case of another.
Supporting documents shows that the complainant provided his name and postal
address when he made his request for access to personal data. Klarna states it had
3 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).
4 EDPB Guidelines 01/2022, paragraph 67
5 EDPB Guidelines 01/2022, paragraph 70.
Swedish Authority Our ref.: IMY-2025-9256 6(9)
for Privacy Protection Date: 2025-11-10
reasonable doubts as to the identity of the complainant, since the complainant only
provided two of several necessary data points in order to be considered, according to
the routine at the time, to be identified before the provided supplementary information
in accordance with Klarna’s request which enabled an identification and subsequently
a disclosure of a copy of his data. Klarna also 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 erasure. 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 customers' identity is not revealed. Financial institutions are particularly vulnerable
to fraud attempts of various kinds and Klarna must ensure that no personal data is
exposed to unauthorized persons and, in case of 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 at the time of the request was made.
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
identification process, all of these possible data points are requested, but not all of
them are necessary for the identification of the data subject. Klarna states that, in the
complaint at issue Klarna asked the complainant to provide six additional data points in
order to identify him. After the complainant provided the requested information, Klarna
required by mistake the complainant to provide the same information.
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
Swedish Authority Our ref.: IMY-2025-9256 7(9)
for Privacy Protection Date: 2025-11-10
context in which the request is made and any damage that may result from undue
disclosure.6
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.
However, according to Klarna itself, not all of the additional information requested was
necessary to identify the complainant. Supporting documents shows that Klarna
repeatedly requested additional information in order to handle the request for access
and that, in doing so, it also requested information which the complainant had already
provided in connection with his request. 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 and
moreover to repeat the request even though the data in question already has been
provided 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.
Klarna has requested the complainant to provide certain information in order to be able
to confirm the complainant’s identity and then further handle the complainant’s request
for access. The complainant has been asked to provide, inter alia, the invoice number,
the name of a merchant the complainant placed an order with and exact invoice
amount for the purchase. As can be seen above, IMY considered that not all the
information requested by Klarna was necessary to identify the complainant. As a
result, the complainant had to carried out research in order to find several items of
information relating, inter alia, to previous purchases, even though such information
was not always necessary. In addition, Klarna has requested the complainant to
provide the information again although the complainant already provided it. 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.
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
6 EDPB Guidelines 01/2022, paragraph 70.
Swedish Authority Our ref.: IMY-2025-9256 8(9)
for Privacy Protection Date: 2025-11-10
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. IMY has also found that Klarna had not facilitated the exercise of the
complainant’s right of access. However, Klarna responded without delay to the
complainant’s e-mails in order to comply with his request for access. Although the
complainant’s right of access was only granted in December 2021, the deficiencies
found are of a less serious nature than if the request had been left unanswered.
In the light of the foregoing, IMY takes the view that these are minor infringements
within the meaning of recital 148 that require Klarna to be given a reprimand under
Article 58(2)(b) of the GDPR for the infringements found.
__________________________
This final decision has been made by , Department Lawyer, following a
presentation by , Legal Advisor.
Appendix
The complainant’s personal data
Copy to
Data Protection Officer
Swedish Authority Our ref.: IMY-2025-9256 9(9)
for Privacy Protection Date: 2025-11-10
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.