Notice: This document is an unofficial translation of the Swedish Authority for
Privacy Protection’s decision. Only the Swedish version is authentic. 1(9)
COMPLAINANT
See appendix
CONTROLLER
Klarna Bank AB
Swedish ref.:
IMY-2025-8259 Final decision under the General Data
Protection Regulation – Klarna Bank
IMI case register:
134712 AB
Date:
2025-12-02
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 dated 22 May 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 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-2025-8259. 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 9
Swedish Authority Our ref.: IMY-2025-8259 2(9)
for Privacy Protection Date: 2025-12-02
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 22 May 2020 the complainant sent
a letter to request access to his personal from Klarna. In the context of its request, the
complainant provided the following information:
- First and last name
- E-mail address
- Postal address
- Phone number.
The complainant also attached a copy of his identity card to his application. On
12 June 2020, Klarna contacted him by email and asked for more information, even
though that information should have been available to Klarna. Klarna requested, inter
alia, the complainant’s name, telephone number, email address, date of birth as well
as information about Klarna’s customer (IKEA). The Complainant replied to the
questions on the same day to the extent possible, stressing that he expected a
response to the request by 22 June 2020. Nevertheless, Klarna did not comply with
the ’s request for 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 on 29 May 2020 (dated 22
May 2020). The request started to be processed on 12 June 2020. On 7 August 2020,
after questions were answered regarding the credit reports allegedly initiated by Klarna
and a discussion about the identification process continued, Klarna informed that the
information provided by the applicant was not sufficient to identify the applicant. As a
result, the request could not be fulfilled.
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
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Swedish Authority Our ref.: IMY-2025-8259 3(9)
for Privacy Protection Date: 2025-12-02
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 had reason to doubt the identity of the complainant as it was unable to verify
the data points (e-mail address, name, date of birth, telephone number and name of
shop) provided by the complainant. 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
• E-mail address that was used for the purchase
• Date of birth
• Invoice number
• Order number
• Name of shop.
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
Page 3 of 9
Swedish Authority Our ref.: IMY-2025-8259 4(9)
for Privacy Protection Date: 2025-12-02
possible data points, but different combinations of those data points have been
possible for the secure identification of the complainant.
Date of birth has been a mandatory data point for identifying customers at the time of
the case. Klarna's procedures are constantly evaluated and developed, and for data
protection cases, the date of birth is no longer a mandatory data point for identification
in Germany. Klarna therefore currently has enough information to identify the
complainant in accordance with our procedures. Klarna therefore intends to contact
the complainant to see if the request is still up-to-date and, if so, provide the
complainant access.
Motivation for 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 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
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-2025-8259 5(9)
for Privacy Protection Date: 2025-12-02
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.
Klarna states that the company was not able to verify the data points provided by the
complainant in connection with the request and that, as a result, it did not have the
information necessary to identify the applicant in accordance with the procedure in
force at the time. 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.
Klarna also stated that it did not have the complainant’s date of birth and that this was
mandatory under the identification procedure in force at the time. On the other hand,
the complainant claims that the date of birth is apparent from his initial request. It is
apparent from the file that the applicant stated in his request dated 22 May 2020 that
complainant attached a copy of his identity card. It is also apparent from the file that, in
the email sent to Klarna on 12 June 2020, the complainant stated that the date of birth
appeared in the request. However, Klarna maintains that it does not have the date of
birth of the complainant.
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. Furthermore, IMY notes that there is no evidence that the complainant has
submitted a copy of his identity card in connection with the request. In the light of the
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Swedish Authority Our ref.: IMY-2025-8259 6(9)
for Privacy Protection Date: 2025-12-02
foregoing, IMY considers that there is no reason to question that Klarna had
reasonable grounds to doubt the identity of the complainant.
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, in addition to her email address, 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
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.
5 EDPB Guidelines 01/2022, paragraph 70.
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Swedish Authority Our ref.: IMY-2025-8259 7(9)
for Privacy Protection Date: 2025-12-02
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.
IMY considers that the verification method was burdensome for the complainant in
such a way as to make it more difficult to exercise the right of access. In making that
assessment, IMY took into account, in particular, the fact that Klarna had requested
information which was already apparent from the complainant’s initial request and that
not all the information requested by Klarna had been necessary to identify the
appellant in the individual case.
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. However, Klarna
responded without delay to the complainant’s letter in order to comply with her request
for access. Klarna has also stated that it now intends to contact the complainant to see
whether the request is still valid and, if so, to send an extract from the register to the
complainant.
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 made by the Legal Counsel after presentation
by legal advisor .
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Swedish Authority Our ref.: IMY-2025-8259 8(9)
for Privacy Protection Date: 2025-12-02
Appendix
The complainant’s personal data
Copy to
Data Protection Officer
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Swedish Authority Our ref.: IMY-2025-8259 9(9)
for Privacy Protection Date: 2025-12-02
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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