publishable_fr_2019-10_right_to_erasure_ignored_summarypublic.pdf

Summary Final Decision Art 60
Complaint

No violation

Background information
Date of final decision: 23 September 2019
LSA: FR
CSAs: DE-Mecklenburg-Western Pomerania, DE-Rhineland-Palatinate, ES
Legal Reference: Right to erasure (Article 17)

Decision: No infringement of the GDPR
Key words: Right to erasure, Electronic communications, Payment data

Summary of the Decision

Origin of the case
The complainant asked for the deletion of his user account on the Spanish version of the controller’s website. In its reply, the controller stated that it was required to keep some of his data. However, it informed the complainant of the date on which all of his data would be entirely deleted.

Findings
The LSA found that, pursuant to national law, the controller was required to retain the complainant’s payment data in an intermediate archive upon the deletion of his user account in order to manage claims and disputes related to a payment made on its platform. In consequence, the controller acted in accordance with Article 17 (3) GDPR when it kept some of the complainant’s data.

Decision
The LSA found that the controller complied with its obligations under the GDPR and closed the case.


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