Take-Aways (AI)
  • The Fede­ral Admi­ni­stra­ti­ve Court qua­li­fi­es the Weko noti­fi­ca­ti­on that it can­not pro­vi­de infor­ma­ti­on as an order with legal effect (defer­ral pur­su­ant to DPA 9).
  • The FADP is appli­ca­ble; third par­ties who are not par­ties to the pro­ce­e­dings may request infor­ma­ti­on about per­so­nal data in pro­ce­e­dings pen­ding befo­re the SNB.
  • The gran­ting of infor­ma­ti­on depends on a balan­cing of inte­rests; the FAC refers the mat­ter back to the Com­pe­ti­ti­on Com­mis­si­on for fur­ther cla­ri­fi­ca­ti­on and consideration.

The FAC had in the pre­sent decis­i­on to deci­de on a request for infor­ma­ti­on from the Com­pe­ti­ti­on Com­mis­si­on (Com­co), reque­st­ing, among other things, a copy of a sanc­tion order inso­far as this rela­ted to the par­ty entit­led to infor­ma­ti­on – which was not a par­ty to the pro­ce­e­dings. The secre­ta­ri­at of the Weko rejec­ted this request. The FAC upheld the appeal against this decision.

Initi­al­ly, it was dis­pu­ted whe­ther the noti­fi­ca­ti­on by the Weko that it could not com­ply with the request for infor­ma­ti­on was a Order acted. The Fede­ral Admi­ni­stra­ti­ve Court ans­we­red this que­sti­on in the affir­ma­ti­ve. In par­ti­cu­lar, in the opi­ni­on of the FAC, the com­mu­ni­ca­ti­on was based on the Achie­ving a legal effect ali­gned: The com­mu­ni­ca­ti­on of the Weko that it was “curr­ent­ly” not pos­si­ble for it to pro­vi­de the infor­ma­ti­on had to be con­side­red here as a legal­ly pro­vi­ded Post­po­ne­ment of the pro­vi­si­on of infor­ma­ti­on within the mea­ning of DSG 9 be under­s­tood. As a result, the legal rela­ti­on­ship has been regu­la­ted in one of the forms pro­vi­ded by law, so that a legal effect is achieved.

The FADP was then appli­ca­ble and in par­ti­cu­lar not exclu­ded by FADP 2 II lit. c (no appli­ca­ti­on to pen­ding admi­ni­stra­ti­ve pro­ce­e­dings), becau­se this pro­vi­si­on pre­sup­po­ses the pen­den­cy of pro­ce­e­dings “in the sen­se that the vali­di­ty of the rele­vant pro­ce­du­ral pro­vi­si­ons is trig­ge­red” (BGE 138 III 425 E. 4.3). Accor­ding to the BVGer, this must not only app­ly – as in the afo­re­men­tio­ned BGE – in tem­po­ral terms, but also in per­so­nal terms: Sin­ce third par­ties not invol­ved in the pro­ce­e­dings can­not invo­ke the cor­re­spon­ding pro­ce­du­ral rights, they must also be able to invo­ke the right of access under data pro­tec­tion law with respect to their per­so­nal data pro­ce­s­sed in con­nec­tion with pro­ce­e­dings that are them­sel­ves pen­ding befo­re the Fede­ral Admi­ni­stra­ti­ve Court.

As a result, the com­plainant was the­r­e­fo­re able to sub­mit a request for infor­ma­ti­on to the Com­co. It was que­stionable, howe­ver, whe­ther a rest­ric­tion had right­ly been impo­sed, which was to be Weig­hing of inte­rests is depen­dent. In this con­text, the com­plainant invo­ked its inte­rest in con­trol­ling the lawful­ness of the data pro­ce­s­sing in con­nec­tion with the sanc­tion order. It must also be able to cla­ri­fy whe­ther it is por­tray­ed in the order in a way that dama­ges its repu­ta­ti­on in the con­text of beha­vi­or that vio­la­tes anti­trust law. The Weko, on the other hand, had argued that the com­plainant was first of all inte­re­sted in inspec­ting the sanc­tion order. Howe­ver, the publi­ca­ti­on of the sanc­tion order is con­te­sted and has not yet been deci­ded in a legal­ly bin­ding man­ner. The FAC con­siders the complainant’s inte­rests to be important, whe­re­as the que­sti­on of publi­ca­ti­on of the sanc­tion order does not affect the que­sti­on of infor­ma­ti­on pur­su­ant to FADP 8. Only the con­fi­den­tia­li­ty inte­rests of the com­pa­nies affec­ted by the inve­sti­ga­ti­on come into con­side­ra­ti­on here. It must the­r­e­fo­re be cla­ri­fi­ed how the­se can be satis­fied. The FAC the­r­e­fo­re refers the mat­ter back to the Comco,