- Schufa, Germany's largest credit reporting agency, maintains a "shadow database" containing historical and outdated financial records for millions of individuals.
- These records are excluded from official data copies provided to consumers, preventing transparency regarding the full extent of their stored data.
- Privacy experts argue that this practice violates data minimization principles and lacks a clear legal basis under GDPR.
Nature and Use of Data
- The database includes sensitive information such as old loans, credit cards, garnishments, and resolved personal insolvencies.
- Schufa utilizes this data to test, develop, and demonstrate the accuracy of its current credit scoring models, as well as for legal defense.
- Investigation revealed that Schufa clients can also access historical credit scores, allowing them to view a person's past creditworthiness.
Legal Contention and Oversight
- Schufa maintains that it is legally required to archive these records and insists that its current disclosure practices fulfill obligations under Article 15 of the GDPR.
- Professor Ruth Janal, an expert in data protection, argues that the storage of such vast datasets for indefinite future purposes violates European Court of Justice precedents.
- The Hessian Data Protection Commissioner has been investigating these data testing practices and the lack of consumer disclosure for over a year.
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