Take-Aways (AI)
  • Art. 15 GDPR grants a com­pre­hen­si­ve right of access to stored and pro­ce­s­sed per­so­nal data, inclu­ding medi­cal docu­ments and expert opinions.
  • The right to infor­ma­ti­on does not include all inter­nal pro­ce­s­ses, notes or cor­re­spon­dence alre­a­dy known to the data sub­ject or legal assess­ments or analyses.
  • The right to a copy is limi­t­ed to the per­so­nal data pro­ce­s­sed; the right of access must not be inter­pre­ted exten­si­ve­ly or misused.

The Regio­nal Court of Colo­gne (LG Colo­gne, AZ 26 O 25/18, March 18, 2019) has beco­me also on the right to infor­ma­ti­on under Art. 15 GDPR expressed:

[From Art. 15 GDPRThis results in a com­pre­hen­si­ve right of access to the per­so­nal data stored or pro­ce­s­sed. […] Accor­ding to the­se prin­ci­ples and on the basis of the reci­tals, medi­cal records, expert opi­ni­ons or other com­pa­ra­ble com­mu­ni­ca­ti­ons from other sources also con­sti­tu­te “per­so­nal data”. In the opi­ni­on of the Board, howe­ver, the right to infor­ma­ti­on does not rela­te to all of the defendant’s inter­nal pro­ce­s­ses, such as memos, or to the fact that the per­son con­cer­ned can have all exch­an­ged cor­re­spon­dence, which is alre­a­dy known to the per­son con­cer­ned, prin­ted out and sent to him again (so the OLG Colo­gne to § 34 BDSG a.F., decis­i­on dated July 26, 2018, 9 W 15/18). In this respect, legal assess­ments or ana­ly­ses also do not con­sti­tu­te per­so­nal data in this sen­se. The cla­im under Art. 15 DS-GVO is not used for sim­pli­fi­ed accoun­ting of the data sub­ject, but is inten­ded to ensu­re that the data sub­ject can assess the scope and con­tent of the per­so­nal data stored. Con­se­quent­ly, Artic­le 15 (3) sti­pu­la­tes DS-GVOthat the per­son con­cer­ned recei­ves a copy of (only) the per­so­nal data that are the sub­ject of the pro­ce­s­sing. In the pre­sent case, the defen­dant has pro­vi­ded various infor­ma­ti­on and details […] and sta­ted that fur­ther per­so­nal data about the plain­ti­ff was not stored or pro­ce­s­sed. The plain­ti­ff has not made any sub­stan­tia­ted sub­mis­si­on as to what other infor­ma­ti­on might have been pro­ce­s­sed by the defendant. […]

In the dis­cus­sion about the scope of the right to infor­ma­ti­on and its abu­se, this sup­ports the view, which is gai­ning ground, that the right to infor­ma­ti­on must not be inter­pre­ted too extensively.