The copy and the relation to the applicant are ensured.
REQUEST PHOTOCOPY OF ID AND CREDIT CARD FULL
Generally, the date of issue or expiry date, the issuing authority and the full name matching with the onlineĪccount are sufficient for the controller to verify the identity, always provided that the authenticity of National legislation requires a full unredacted copy of the identity card (see para. May be blackened or hidden by the data subject before submitting it to the controller, except where Such as the access and serial-number, nationality, size, eye colour, photo and machine-readable zone, “ In any case, information on the ID that is not necessary for confirming the identity of the data subject, via e-mail or text message containing confirmation links, security questions or confirmation codes.” Information on the ID that is not necessary for confirming the identity should be hidden Their clients’ ID card, it should generally not be considered an appropriate way of authentication.Īlternatively, the controller may implement a quick and effective security measure to identify a data subject who has been previously authenticated by the controller, e.g. hotels, banks, car rentals) request copies of Taking into account the fact, that many organisations (e.g.
/ In general, the fact that the controller may request additional information to assess the data subject’s identity cannot lead to excessive demands and to the collection of personal data which are not relevant or necessary to strengthen the link between the individual and the personal data requested.” Copy of ID card should generally not be considered an appropriate way of authentication in order to avoid excessive data collection.” Do not excessively demand for personal data when validation of access request “The request for additional information must be proportionate to the type of data processed, the damage that could occur etc. The controller should provide appropriate and user-friendly communication channels that can easily be used by the data subject.” “There are no specific requirements on the format of a request.
It has been a part of the European data protection legal framework since its beginning and is now further developed by more specified and precise rules in Art. 8 of the EU Charter of Fundamental Rights. The EDPB explains in the executive overview of their guidelines that “ The right of access of data subjects is enshrined in Arti. EDPB guidelines Guidelines 01/2022 on data subject rights – Right of access The highlights Using your identity data, people can open bank accounts and credits, steal your many, empty your existing bank account, … so the impact is very personal, very real and very high when your identity is stolen. The copy of the ID card contains a lot of sensitive data like your national number, that can be abused to harm you, by stealing your identity. In the motivation of the case it sets a very clear reminder that it’s considered illegal to systematically request for a copy of an identity card as a condition to respond to a GDPR data access request, in accordance with the EDPB (European Data Protection Board) guidelines on the right to access. A very clear reminder that you shall not systematically request a copy of the identity card In a recent publication of a case (DOS-2020-05314), the Belgian Data protection Authority decided to classify the complaint itself without any consequences, but they explicitly confirmed that the use of a photocopy of the ID card is a very bad idea in general. This article is not elaborating all of it, but only highlights the topics relative to the use of ID card photocopies, as there has been a recent case at the Belgian Data Protection Authority strongly referring to the data access request guidelines by the European Data Protection board (EDPB). The EDPB guidelines on the data subject’s rights of access contain 60 pages of very useful instructions.
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