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GDPR Guide to National Implementation: Germany

A practical guide to national GDPR compliance requirements across the EEA

Germany

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In this chapter:

Q1/ Applicable legislation

Q2/ Personal data of deceased persons

Q3/ Legal bases for processing

Q4/ Consent of children

Q5/ Processing of sensitive personal data

Q6/ Data relating to criminal offences or convictions

Q7/ Exemptions

Q8/ Restrictions on data subjects’ rights

Q9/ Joint controllership

Q10/ Processor

Q11/ Data protection Impact Assessments

Q12/ Prior authorisation and public interest

Q13/ DPOs

Q14/ International data transfers

Q15/ DPAs

Q16/ Claims by not-for-profit bodies

Q17/ Administrative fines, penalties and sanctions

Q18/ Freedom of expression and information

Q19/ National identification numbers

Q20/ Processing in the context of employment

Q21/ Other material derogations

Q22/ Current legal challenges

Q23/ Enforcement

Q24/ Regulatory Guidance

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Q1/ Applicable legislation

(a) Have the requirements of the GDPR been addressed by introducing a new law, or by updating existing legislation?

Old legislation has been updated.

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(b) Relevant legislation includes:

  • Bundesdatenschutzgesetz, Neufassung 2018 (“BDSG“)
    • Date in force: 25 May 2018
    • Link: In German: see here 

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(c) What is the status of national pre-GDPR data protection law?

The relevant pre-GDPR legislation has been revised. To date, more than 150 pieces of legislation have been updated.

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Q2/ Personal data of deceased persons

Does national law make specific rules regarding the processing of personal data of deceased persons?

There are no specific rules governing this issue.

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Q3/ Legal bases for processing

(a) Does national law make specific rules regarding the processing of personal data in compliance with a legal obligation?

There are no general rules governing this issue at the level of the BDSG.

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(b) Does national law make specific rules regarding the processing of personal data for the performance of tasks carried out in the public interest?

Public bodies are permitted to process personal data if such processing is necessary to perform a task for which the relevant body is responsible, or to exercise official authority which has been vested in the controller.

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(c) Does national law make specific rules regarding the processing of personal data in the exercise of official authority vested in the controller?

See Q3(b) above.

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(d) Does national law contain criteria in addition to those listed in the GDPR, to determine whether processing for a new purpose is compatible with the purpose for which the personal data were initially collected?

Public bodies can process personal data for a new purpose if such processing is necessary with respect to their duties in the following situations:

  • the relevant processing is in the interest of the data subject;
  • to check information provided by the data subject;
  • to prevent substantial harm to the common good or a threat to public security, defence or national security;
  • to safeguard substantial concerns of the common good;
  • to ensure tax and customs revenues;
  • to prosecute criminal or administrative offences and enforce certain punishments and related measures;
  • to prevent serious harm to the rights of another person; or
  • to exercise powers of supervision and monitoring (including audits of the relevant body).

Private bodies may process personal data for a new purpose in the following situations, provided that the data subject has no overriding interest:

  • to prevent threats to state or public security or to prosecute criminal offences; or
  • for the establishment, exercise or defence of legal claims.

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Q4/ Consent of children

At what age can a child give their consent to processing in relation to ISS?

16 years of age.

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Q5/ Processing of sensitive personal data

(a) Are there any sensitive personal data which cannot be processed on the basis of a data subject’s consent?

All sensitive personal data can be processed if the data subject’s valid consent has been obtained.

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b) Does national law contain any specific requirements regarding the processing of sensitive personal data in respect of the following:

(i) Employment, social security and/or social protection law

Sensitive personal data processed for employment-related purposes may be processed to exercise rights or comply with legal obligations derived from labour law, social security and social protection law, unless the data subject’s legitimate interest overrides the necessity of the processing.

In addition, the processing of sensitive personal data for employment reasons can be based on collective agreements. If the processing of (sensitive) personal data of employees is based on consent, the employee’s bargaining power and the circumstances under which consent was given must be taken into account in assessing whether such consent was freely given. Consent may be freely given if it is associated with a legal or economic advantage for the employee, or if the employer and employee are pursuing the same interests. Consent must generally be given in written or electronic form.

(ii) Substantial public interest

The following rules apply to the processing of this category of data:

  • public bodies may process sensitive personal data in the following circumstances (provided that the interests of the controller outweigh the interests of the data subject):
    • if such processing is mandatory to uphold a substantial public interest;
    • to prevent a substantial threat or harm to public security or a common good or to safeguard substantial concerns of the common good;
    • for mandatory reasons of defence; or
    • to fulfil supra- or intergovernmental obligations in the field of crisis management or conflict prevention, or for humanitarian measures; and
  • public and private bodies may process sensitive personal data to exercise the applicable laws relating to social security and social protection.

(iii) Preventative or occupational medicine; employee working capacity, medical diagnosis, provision of health or social care, or management of health or social care systems or services

Public and private bodies may process sensitive personal data in the following circumstances:

  • for preventative or occupational medicine, employee working capacity, medical diagnosis, provision of health or social care, or management of health or social care systems or services; or
  • pursuant to the data subject’s contract with a health care professional, and if the processing is subject to secrecy.

(iv) Public interest in the area of public health

Public and private bodies may process sensitive personal data for reasons of public interest in the area of public health. The processing needs to comply with occupational and criminal law safeguards relating to professional secrecy.

(v) Archiving purposes, scientific or historical research purposes or statistical purposes

The following rules apply to the processing of this category of data:

  • the processing of sensitive personal data is permitted if necessary for archiving purposes in the public interest; and
  • sensitive personal data may be processed without consent for scientific or historical research purposes or statistical purposes provided that the interests of the controller substantially outweigh those of the data subject.

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(c) Has national law introduced any further conditions and/ or limitations with regard to the processing of genetic data, biometric data, or health data?

Processing of this category of personal data is subject to a number of different legal requirements in Germany. Key examples of such requirements include the following:

  • processing genetic data for examination or analysis is only permitted if the data subject has consented in an explicit and written manner;
  • fingerprints processed as biometric data may only be stored on an identity card at the request of the card applicant; or
  • health data processed on the basis of necessity for the performance of tasks related to infection prevention must be deleted once the personal data are no longer required for the performance of the tasks.

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Q6/ Data relating to criminal offences or convictions

Under what conditions does national law permit the processing of personal data relating to criminal convictions?

There are no specific rules on processing this category of data.

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Q7/ Exemptions

(a) Does national law specify exemptions to a data subject’s right to erasure?

Where non-automated processing has been carried out, a data subject cannot exercise his or her right to erasure if the following criteria apply:

  • where erasure would be impossible or would involve a disproportionate effort due to the specific mode of storage;
  • the data subject’s interest in erasure can be regarded as minimal; and
  • the personal data have not been unlawfully processed.

The data subject may, however, request the restriction of processing in accordance with Art. 18 GDPR.

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(b) Does national law specify exemptions to a data subject’s right to be provided information under Art. 14 GDPR where the personal data has not been obtained from the data subject?

The right of the data subject pursuant to Art. 14 GDPR does not apply, if providing information would achieve any of the following:

  • would endanger the proper performance of tasks of a public body as referred to in Art. 23(1)(a)-(e) GDPR;
  • would threaten public security or public order, or otherwise be detrimental to the Federal Republic of Germany or a federal state;
  • would interfere with the establishment, exercise or defence of legal claims (unless the data subject has an overriding legitimate interest in receiving the information);
  • the processing includes personal data from private law contracts and is intended to prevent harm from criminal offences (unless the data subject has an overriding legitimate interest in receiving the information); or
  • if granting access to the personal data would disclose information which, by its nature, must be kept secret (in particular, where a third party has overriding legitimate interests with respect to such data).

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(c) Does national law specify exemptions to a data subject’s right to not be subject to a decision based solely on automated processing, including profiling?

A data subject may not be subject to such a decision if the decision is made in the context of providing services pursuant to an insurance contract, and the request of the data subject was fulfilled, or the decision is based on the application of binding rules of remuneration for therapeutic treatment, and the controller takes suitable measures. Suitable measures must include, as a minimum, the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision in case the request was not granted.

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Q8/ Restrictions on data subjects’ rights

Aside from the exemptions noted in Q7, does national law contain any other restrictions on the rights of data subjects under Chapter III GDPR?

Where personal data have been obtained directly from the data subject, the right to information with respect to further processing (Art. 13(3) GDPR) does not apply in the following circumstances:

  • in the context of a client-lawyer relationship, if the personal data of third persons are transferred to persons subject to a legal obligation of professional secrecy, unless the data subject has an overriding interest in being informed;
  • if providing information would interfere with the establishment, exercise or defence of legal claims, and the controller’s interests in not providing the information outweigh the interests of the data subject;
  • if providing information would endanger a confidential transfer of data to public bodies;
  • in case of further processing of data stored in analogue form, for which the controller directly contacts the data subject through the further processing; the communication with the data subject does not take place in digital form; and the interest of the data subject in receiving the information can be regarded as minimal;
  • in the case of a public body, if providing information would endanger the proper performance of tasks as referred to in Art. 23(1)(a)-(e) GDPR; or
  • if providing information would endanger public security or order, or would otherwise be detrimental to the welfare of the Federal Republic of Germany, or a federal state.

The right of access (Art. 15 GDPR) does not apply in the following circumstances:

  • if granting access to the personal data would disclose information which, by law or by its nature, must be kept secret (in particular where a third party has overriding legitimate interests);
  • if the personal data were recorded only because retention of the relevant personal data is required to comply with applicable law, and disclosure would require disproportionate effort;
  • if the personal data is processed to monitor compliance with data protection law or to safeguard other personal data, and disclosure would require disproportionate effort;
  • in the case of a public body, if providing information would endanger public security or order, or would otherwise be detrimental to the welfare of the Federal Republic of Germany or a federal state;
  • if disclosure is likely to render impossible or seriously impair processing for research or statistical purposes;
  • if the data are necessary for purposes of scientific research, and disclosure would involve disproportionate effort;
  • if disclosure involves searching archival material which is not identified with the relevant data subject’s name or if insufficient information is provided in the access request so as to enable the relevant archival material to be found using reasonable effort; or
  • in the case of a public body, if providing information would endanger the proper performance of the tasks set out in Art. 23(1)(a)-(e) GDPR.

The right to rectification (Art. 16 GDPR) does not apply in the following circumstances:

  • if it is likely to render impossible or seriously hinder processing for research or statistical purposes, and limiting the exercise of the right is necessary for the fulfilment of the research or statistical purposes; or
  • if the personal data are processed for archiving purposes in the public interest.

Where the second set of circumstances apply, the data subject who disputes the accuracy of his or her personal data may submit the personal data which he or she believes to be accurate.

The right to restriction of processing (Art. 18 GDPR) does not apply in the following circumstances:

  • if it is likely to render impossible or seriously hinder processing for research or statistical purposes, and limiting the exercise of the right is necessary for the fulfilment of the research or statistical purposes; or
  • as provided in Art. 18(1)(a), (b) & (d) GDPR, if it is likely to render impossible or seriously impair processing for archiving purposes in the public interest, and limiting the exercise of this right is necessary to fulfil those purposes.

The right to data portability (Art. 20 GDPR) does not apply if it is likely to render impossible or seriously impair processing for archiving purposes in the public interest, and limiting the exercise of this right is necessary to fulfil those purposes.

The right to object (Art. 21 GDPR) does not apply in the following circumstances:

  • if this right is likely to render impossible or seriously hinder processing for research or statistical purposes, and limiting the exercise of this right is necessary for the fulfilment of the research or statistical purposes;
  • if it is likely to render impossible or seriously hinder processing for archiving purposes in the public interest, and limiting the exercise of this right is necessary to fulfil those purposes; or
  • with regard to a public body, if there is an urgent public interest in the processing which outweighs the interests of the data subject, or if processing is required by law.

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Q9/ Joint controllership

Does national law provide rules or guidance on the apportionment of responsibility between joint controllers?

There are no additional rules on apportionment of liability between joint controllers.

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Q10/ Processor

In addition to the contract between controller and processor, are there any pieces of legislation which govern processing by a processor?

There are no additional pieces of legislation that apply in general.

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Q11/ Impact Assessments

Are there any circumstances in which national law requires an Impact Assessment to be carried out, where the GDPR would not otherwise require such an assessment?

Impact Assessments are only required in accordance with the provisions of the GDPR.

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Q12/ Prior authorisation and public interest

Are there any circumstances in which national law requires controllers to consult with, or obtain prior authorisation from, the DPA in relation to processing for the performance of a task carried out by the controller in the public interest (including processing in relation to social protection and public health)?

Prior authorisation from the DPA is only required in accordance with the provisions of the GDPR.

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Q13/ DPOs

(a) Does national law require controllers to appoint a DPO in circumstances other than those in Art. 37(1) GDPR?

A controller or a processor must designate a DPO in the following circumstances:

  • if it constantly employs at least 20 persons dealing with the automated processing of personal data;
  • if it undertakes processing subject to an Impact Assessment pursuant to Art. 25 GDPR; or
  • if it commercially processes personal data for the purpose of transferring it (including anonymised transfer), or for the purpose of market or opinion research.

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(b) Does national law impose secrecy and confidentiality obligations on DPOs and if so, in what circumstances do they apply?

DPOs (of both public and private entities) are bound by secrecy when contacted by a data subject, with respect to the identity of the data subject and concerning circumstances enabling the data subject to be identified, unless the DPO is released from this obligation by the relevant data subject.

DPOs at entities or businesses that are subject to professional secrecy (such as physicians, psychologists, lawyers, public officials, work councils) may be liable for imprisonment or a fine if they violate the obligation of secrecy.

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Q14/ International data transfers

(a) Does national law make specific rules about transfers of personal data from public registers?

Data transfers from public registers are not subject to specific rules.

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(b) Does national law restrict the transfer of specific categories of personal data to third countries?

Data transfers are not subject to restrictions beyond those set out in the GDPR.

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Q15/ DPAs

(a) Details of the DPA(s).

  • Name of DPA: The Federal Commissioner for Data
    Protection and Freedom of Information (German:
    Der Bundesbeauftragte für den Datenschutz und die
    Informationsfreiheit) (the “Federal DPA”) is the Joint
    Representative of the German DPAs (see Q15(b)) in the
    European Data Protection Board

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(b) If more than one national DPA has been established, what is the rationale behind multiple DPAs?

Multiple DPAs exist because of Germany’s federal structure. Therefore, the Federal Republic of Germany, as well as each federal state, has established its own DPA.

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(c) How does national law ensure consistent application of the GDPR by the various DPAs in accordance with Art. 63 GDPR?

The Federal DPA and the federal states’ DPAs work together on EU matters with the aim of consistently applying the GDPR. Before submitting a common position to the DPAs of the other Member States, the Commission or the EDPB, the Federal DPA and the federal states’ DPAs give each other the opportunity to comment at an early stage and share relevant information.

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(d) Does national law grant the relevant DPA additional powers beyond those set out in Art. 58 GDPR?

The law in Germany grants the DPAs the following additional powers:

  • the federal states’ DPAs monitor the application of data protection legislation by private bodies;
  • if a DPA determines that data protection legislation has been violated, it can inform the affected data subjects, report the violation to other bodies responsible for prosecution or punishment and, in the case of serious violations, notify the relevant industry regulator to take measures under trade and industry law;
  • entities subject to monitoring and the persons responsible for their management must provide a DPA, on request, with the information necessary to perform its tasks;
  • DPAs may process the personal data they have stored only for purposes of supervision; to this end, they may transfer personal data to other DPAs. Processing for another purpose is permitted in addition to Art. 6(4) GDPR in the following cases:
    • if it is clearly in the interest of the data subject, and there is no reason to assume that the data subject would refuse consent if he or she were aware of the other purpose;
    • if processing is necessary to prevent substantial harm to the common good or a threat to public security, or to safeguard substantial concerns of the common good; or
    • if processing is necessary to prosecute crimes or administrative offences, to carry out or enforce punishment or fines in accordance with the applicable law;
  • persons assigned by the DPA to monitor compliance with data protection legislation are authorised, to the extent needed to perform their tasks, to enter the property and access all data processing equipment and personnel. The relevant entity must provide the DPA with the following:
    • access to all premises at all times, including to any data processing equipment, and to all personal data and all information necessary to perform its tasks; and
    • information necessary to perform its tasks; and
  • the DPAs advise and support the DPOs in the performance of their tasks. The DPAs may demand the dismissal of a DPO if he or she does not have the expert knowledge needed to perform his or her tasks, or if there is a serious conflict of interests as referred to in Art. 38 GDPR.

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(e) What national appeals process exists to enable parties to challenge the decisions of the DPA?

With the exception of administrative fine proceedings, administrative legal action is available where the Code of Administrative Court Procedure applies. For administrative fine proceedings, the administrative fine procedures pursuant to the Act on Regulatory Offences is available.

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(f) Have specific national rules been adopted regarding the DPA’s power to obtain information from controllers or processors that are subject to obligations of professional secrecy (or equivalent)?

DPAs may not obtain information from controllers or processors that are subject to obligations of professional secrecy (or equivalent). Obligations of secrecy also apply to DPAs in the context of their investigations.

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Q16/ Claims by not-for-profit bodies

Does national law specify any not-for-profit bodies that are entitled to bring claims on behalf of individuals without the specific mandate of those individuals?

It is currently unclear whether a violation of the GDPR is sufficient to found a claim against a competitor under the Injunction Act (Unterlassungsklagegesetz). Pursuant to the Injunction Act, consumer organisations may bring collective actions in the interests of consumers regarding processing in the context of advertising, market and opinion research, credit bureaus, the creation of personality and usage profiles, address trading and similar commercial purposes. It is unclear at this point whether such rights of consumer organisations are compatible with Art. 80(2) GDPR. The German Federal Court has not reached a decision on this yet.

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Q17/ Administrative fines, penalties and sanctions

(a) Does national law lay down rules on whether and to what extent administrative fines may be imposed on public authorities for breaches of the GDPR?

Public authorities and other public bodies are not subject to administrative fines.

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(b) Does national law impose penalties/sanctions in addition to those set out in the GDPR, for breaches of the GDPR not subject to administrative fines (e.g., criminal penalties)?

The following additional penalties/sanctions are available:

  • transferring personal data of a large number of people to a third party without authorisation (where the personal data was not previously publicly available), or otherwise making such data accessible for commercial purposes, is punishable with imprisonment of up to three years or a fine; and
  • processing personal data which are not publicly accessible without authorisation, or fraudulently acquiring the data and doing so in return for payment or with the intention of enriching oneself or someone else or harming someone, is punishable with imprisonment of up to two years or a fine.

The above offences will only be prosecuted if a complaint is filed. The data subject, the controller, the Federal DPA and the competent federal state DPA may file complaints.

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Q18/ Freedom of expression and information

(a) What (if anything) does national law do to balance the provisions of the GDPR against the right to freedom of expression and information?

There are no specific provisions governing this issue.

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(b) What derogations have been introduced by national law concerning the processing of personal data for the purpose of academic, artistic or literary expression?

There are no specific provisions governing this issue.

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Q19/ National identification numbers

Does national law stipulate specific conditions for the processing of a national identification number, and if so, what are the conditions?

There are no specific provisions governing this issue.

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Q20/ Processing in the context of employment

(a) For what purposes can employees’ personal data in the employment context be processed under national law?

Personal data of employees may be processed for employment-related purposes where necessary for hiring decisions or, after hiring, for carrying out or terminating the employment contract or to exercise or satisfy rights and obligations of employees’ representation laid down by law or by collective agreements, or other agreements between the employer and staff council.

Furthermore, employees’ personal data may be processed to detect crimes only if there is a documented reason to believe the data subject has committed a crime while employed, the processing of such data is necessary to investigate the crime and is not outweighed by the data subject’s legitimate interest in not processing the data. The type and extent of processing must not be disproportionate to the purpose of the processing.

The processing of personal data, including sensitive personal data of employees for employment-related purposes, will be permitted on the basis of collective agreements. For further details on the processing of sensitive personal data, see Q5(b)(i) above.

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(b) Does national law provide safeguards for employees’ dignity, legitimate interests, and fundamental rights?

The following safeguards apply in order to protect employees’ dignity, legitimate interests and fundamental rights:

  • if personal data of employees are processed on the basis of consent, then the employee’s bargaining power and the circumstances under which consent was given must be taken into account in assessing whether such consent was freely given; and
  • in general, the controller must take appropriate measures to ensure compliance with the GDPR, and, in particular, with the principles for processing personal data contained in Art. 5 GDPR.

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Q21/ Other material derogations

Are there any other material derogations from, or additions to, the GDPR under national law?

Profiling: Pre-contractual profiling is only permitted if the following criteria are met:

  • the personal data used to calculate the probability value are mathematically essential for the calculation;
  • other personal data in addition to address data are used; and
  • if address data are used, the data subject was notified ahead of time of the planned use of these personal data.

Provided the above criteria are met, probability values provided by credit reporting agencies may be used, but only if legally binding claims (as specified in the BDSG) that have not been rendered on time, have been considered. If an entity refuses to conclude a consumer loan contract or a contract concerning financial assistance for payment with a consumer as the result of information provided by a credit agency, the relevant data subject must be immediately notified of this refusal and the information provided by the credit agency must be shared with them. The data subject need not be notified if doing so would endanger public security or order.

CCTV in public spaces: Provided that there is nothing to indicate legitimate overriding interests of the data subjects, CCTV of publicly accessible areas is only permitted as far as it is necessary:

  • for public bodies to perform their tasks;
  • to exercise the right to determine who is permitted or denied access; or
  • to safeguard legitimate interests for specifically defined purposes.

Further, protecting the lives, health and freedom of persons present must be regarded as a very important interest where CCTV is being implemented in the following facilities:

  • large publicly accessible facilities, such as sport facilities, places of gathering and entertainment, shopping centres and car parks; or
  • vehicles and large publicly accessible facilities of public rail, ship or bus transport.

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Q22/ Current legal challenges

Are there any current legal challenges (e.g., court cases or regulatory appeals) regarding the validity or operation of the national GDPR implementation law (e.g., claims that the law incorrectly applies the GDPR; claims that the law is incompatible with constitutional principles; etc.)?

It is currently disputed whether a violation of the GDPR can serve as a claim under the Act Against Unfair Competition (UWG). For this to be the case, the GDPR provisions would need to have a “market behaviour regulation character”. In addition to data subjects and, under certain conditions, non-profit bodies, competitors of an infringer would then be able to claim for infringements of data protection law. The German Federal Court has not reached a decision on this yet.

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Q23/ Enforcement

Has the local DPA issued any material fines or taken any material enforcement action to date for breaches of the GDPR?

The DPAs have taken enforcement action for breaches of the GDPR, including an administrative fine of €20,000 issued by the DPA of Baden-Württemberg. The fine was levied following a hacker attack that resulted in the personal data of around 330,000 users being stolen and then published. This data breach was made possible because the affected company had stored its users’ passwords unencrypted in plain text (a breach of Art. 32(1)(a) GDPR). However, the fine was modest, due to the cooperation of the company with the DPA, its transparency and the high speed with which measures to improve IT security were implemented after the data breach became known.

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Q24/ Regulatory Guidance

Has the DPA issued any significant guidance on the application of the GDPR or national implementation law?

The DPAs have issued the following guidance on the application of the GDPR and/or GDPR implementation law:

  • general guidance issued by the Federal DPA (see here (in German)); and
  • short guidance on different provisions of the GDPR and the BDSG issued jointly by the Federal DPA and the federal states’ DPAs (see here (in German)).

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White & Case contributors

Detlev Gabel

Detlev Gabel
Partner, White & Case
T +49 69 29994 1528
E [email protected]

Dr. Detlev Gabel is a partner in the Frankfurt office and head of White & Case EMEA Data, Privacy & Cybersecurity Practice. He advises multinational clients on a broad range of data protection and security matters, including European and German data protection law compliance, international data transfers and information governance issues. He frequently publishes and speaks on topics relating to the aforementioned areas. Notably, he is the co-editor and co-author of a highly regarded treatise on data protection law, and used to lecture for almost ten years on data protection law at the University of Oldenburg, Germany, in a course leading to a Master of IT Law. The relevant legal directories consistently list him as a leading individual for data protection law in Germany.

Anna Dold

Anna Dold
Associate, White & Case
T +49 69 29994 1203
E [email protected]

As an associate in the Frankfurt office, Anna Dold is advising national and international companies in the areas of data protection and technology law. Her practice focuses on assisting clients on a broad range of data protection matters, including European and German data protection law compliance and international data transfers.

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Other chapters

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See also:

Our Global Data, Privacy & Cybersecurity Practice »

GDPR Handbook: Unlocking the EU General Data Protection Regulation »

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