Notice: This document is an unofficial translation of the Swedish Authority for
Privacy Protection’s final decision. Only the Swedish version is authentic. 1(8)
COMPLAINANT
See appendix
CONTROLLER
Klarna Bank AB
Swedish ref.:
IMY-2025-8304 Final decision under the General Data
German ref: Protection Regulation – Klarna Bank
521.13799/631.315
IMI case register:
AB
CR134712
Date:
2025-11-26
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 5 July 2020 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.
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
Postal address: when Klarna requested data to identify the complainant and facilitated the
Box 8114 complainant’s exercise of its right of access in accordance with Article 12(2) of the
104 20 Stockholm GDPR. The investigation in the case concerns Klarna’s handling of the complainant’s
Sweden
request for access made on 5 July 2020. IMY will therefore not take a position on
Website:
www.imy.se
1 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of
E-mail:
[email protected] natural persons with regard to the processing of personal data and on the free movement of such data, and repealing
Directive 95/46/EC (General Data Protection Regulation).
Telephone: 2 IMY initiated supervision in response to 29 complaints but on 23 September 2023 the complainant withdrew
+46 (8) 657 61 00 complaint 14 (DI-2021-5908).
Swedish Authority Our ref.: IMY-2025-8304 2(8)
for Privacy Protection Date: 2025-11-26
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. The complainant has on 5 July 2020
requested through mail access to her personal data pursuant to Article 15 of the
GDPR.
The complainant has in the context of her request made given Klarna her first- and last
name and her postal address.
Klarna has responded to the complainant and requested at least on two occasions the
following information in order to handle her request:
• Date of birth
• E-mail address used for a purchase with Klarna
• Klarna invoice number for one of the orders
• Name of a trader the complainant placed an order with
• Exact invoice amount for one of the orders
• Transaction-ID and IBAN if the complainant has used Klarna Open Banking
through a third-party provider and access to the personal data stored by it.
Klarna has also requested a telephone number to send a password to the complainant
so that she can open a copy of the personal data.
The complainant has objected to provide the requested information and does not
consider them necessary to handle her request.
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 13 July 2020 and
started the identification process on 14 July 2020 which could not be completed due to
the lack of additional information from the complainant. The complainant has stated
that she will not provide additional information and Klarna has informed the
complainant that identification is a requirement for sending a copy of her personal
data. A discussion on the identification process has continued and Klarna has
informed the complainant that the information she has provided is not sufficient to
Swedish Authority Our ref.: IMY-2025-8304 3(8)
for Privacy Protection Date: 2025-11-26
identify her. As the complainant has not provided the requested information, the
identification process could not be completed.
In the context of meetings between Klarna and the supervisory authority in Berlin from
June to August 2021, a copy of the complainant’s personal data was sent to the
complainant by post on 13 August 2021.
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 her name, i.e. one 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.
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.
Klarna has also requested a telephone number to send a password to the complainant
in order for her to be able to open a copy of the personal data.
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
Swedish Authority Our ref.: IMY-2025-8304 4(8)
for Privacy Protection Date: 2025-11-26
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
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
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
Swedish Authority Our ref.: IMY-2025-8304 5(8)
for Privacy Protection Date: 2025-11-26
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 controller should implement an authentication procedure in order to be
certain of the identity of the persons requesting access to their data, and ensure
security of the processing throughout the process of handling an access request
in accordance with Art. 32 GDPR, including for instance a secure channel for
the data subjects to provide additional information. The method used for
authentication should be relevant, appropriate, proportionate and respect the
data minimization principle. If the controller imposes measures aimed at
authentifying the data subject which are burdensome, it needs to adequately
justify this and ensure compliance with all fundamental principles, including data
minimization and the obligation to facilitate the exercise of data subjects’ rights
(Art. 12(2) GDPR).6
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.
As supporting documents in the matter may be understood, the complainant provided
her first and last name and her postal address when she made her request for access
to Klarna. Klarna has stated that the complainant only provided her name and that
Klarna had reasonable doubts as to the identity of the complainant, since the
complainant only provided one of several necessary data points in order to be
5 EDPB Guidelines 01/2022, paragraph 70.
6 EDPB Guidelines 01/2022, paragraph 71.
Swedish Authority Our ref.: IMY-2025-8304 6(8)
for Privacy Protection Date: 2025-11-26
considered, according to the routine at the time, to be identified. 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. This applies regardless that the
complainant provided both her first and last name and her postal address.
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 five additional data points
in order to identify her.
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-2025-8304 7(8)
for Privacy Protection Date: 2025-11-26
context in which the request is made and any damage that may result from undue
disclosure.7
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. 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 information on, inter alia, the invoice
number, the name of a trader at which the complainant had previously made a
purchase and the exact amount of the invoice. 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 needs to carry 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
In case of deficiencies, IMY may take certain corrective actions. 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. 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
7 EDPB Guidelines 01/2022, paragraph 70.
Swedish Authority Our ref.: IMY-2025-8304 8(8)
for Privacy Protection Date: 2025-11-26
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 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 letters in order to comply with her request for access. Although the
complainant’s right of access was only granted in August 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 taken by , Department Lawyer, following a
presentation by , Legal Advisor.
Appendix
The complainant’s personal data
Copy to
Data Protection Officer
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.