Take-Aways (AI)
  • The plain­ti­ff is not entit­led to the trans­for­ma­ti­on and release of uns­truc­tu­red data on data car­ri­ers; it must take over the data its­elf at its own expen­se, with three months’ access and support.
  • The plain­ti­ff is not entit­led to a cla­im for dele­ti­on and accoun­ta­bi­li­ty: Con­trac­tual­ly and under data pro­tec­tion law, the­re is no obli­ga­ti­on to com­ple­te­ly dele­te or sub­mit access logs.

The Zurich Com­mer­cial Court had ruled in the legal­ly bin­ding Judgment HG150185‑O of May 15, 2017 to rule on the fol­lo­wing legal request:

1a. The defen­dant is to be obli­ga­ted, all data stored on their ser­ver the plain­ti­ff on a Data car­ri­er in a stan­dard for­mat to the appli­cant To be published;

1b. In the alter­na­ti­ve, the defen­dant is to be orde­red to pro­vi­de the plain­ti­ff, at its own expen­se, with the Inter­faces to make the data rea­da­ble and trans­fera­ble for the plaintiff;

2. the defen­dant is to be obli­ged to store this data com­pre­hen­si­ve­ly on its ser­ver and, if neces­sa­ry, on other data car­ri­ers to which the defen­dant has access, after han­ding it over to the plain­ti­ff, irre­vo­ca­ble and veri­fia­ble (con­fir­ma­ti­on by SAP spe­cia­list) to dele­te;

3. that the defen­dant be orde­red to pay to the plain­ti­ff by means of access pro­to­cols and/or other docu­ments show­ing access to the plaintiff’s data in the G._____ system and, if neces­sa­ry, by con­sul­ting an SAP expert, Account for their obli­ga­ti­ons with regard to data pro­tec­tion in accordance with the agree­ment and the Data Pro­tec­tion Act.

all with costs and com­pen­sa­ti­on con­se­quen­ces inclu­ding the legal value added tax of 8 % at the expen­se of the defendant.”

The back­ground was as follows:

  • Dis­pu­te bet­ween a tra­vel agen­cy (plain­ti­ff) and a major Swiss tra­vel pro­vi­der (defen­dant);
  • the tra­vel agen­cy work­ed for a long time with a SAP-based boo­king system of the defen­dant, wher­eby the data ente­red by the plain­ti­ff stored on the ser­vers of the defen­dant were.
  • The under­ly­ing con­tract was ter­mi­na­ted in 2013 as part of a court sett­le­ment, whereu­pon the plain­ti­ff was no lon­ger able to make muta­ti­ons for a cer­tain peri­od of time, but was able to access the system and its data. The plain­ti­ff then expor­ted the struc­tu­red data stored with the defen­dant; with respect to uns­truc­tu­red data howe­ver, export­ing in a stan­dard for­mat was not possible.
  • The con­tract bet­ween the par­ties did not expli­ci­t­ly com­ment on the issue of data migra­ti­on upon ter­mi­na­ti­on of the contract.

The plain­ti­ff sub­se­quent­ly deman­ded by way of action for the sur­ren­der and sub­se­quent dele­ti­on of all data it had stored with the defen­dant and account for access to that data.

On the cla­im for surrender:

Regar­ding the cla­im for resti­tu­ti­on, the HGer:

  • A “show” mode, whe­re stored data is mere­ly dis­play­ed, is not to be inter­pre­ted as regu­la­ting data migration.
  • An ASP con­tract that does not com­ment on data migra­ti­on is patchy.
  • In the case of data to which the Licen­see is eco­no­mic­al­ly entit­led but which is stored in the Provider’s sphe­re of con­trol, the fol­lo­wing shall app­ly “espe­ci­al­ly Par­al­lels to the law of depo­sit”, “in which Art. 475 para. 1 CO grants the depo­si­tor a man­da­to­ry right of reco­very at any time”. Accor­din­gly, howe­ver, the­re would be no obli­ga­ti­on on the part of the pro­vi­der to store the data on a car­ri­er and to hand it over to the licen­see, and the licen­see would have to pay the costs of han­ding over the data. Howe­ver, the right of depo­sit (as well as the right to rent or lea­se and the right to com­mis­si­on) can­not be used wit­hout fur­ther ado, becau­se it is data are not things.
  • The hypo­the­ti­cal will of honest par­ties must the­r­e­fo­re be deter­mi­ned. They would have cho­sen one of the fol­lo­wing two vari­ants: (1) The Licen­see is obli­ged to, their data to take over inde­pendent­ly, uns­truc­tu­red data manu­al­ly. (2) The Pro­vi­der is obli­ged, also to issue the uns­truc­tu­red data in a stan­dard for­mat, but is entit­led to Reim­bur­se­ment of costs for the trans­for­ma­ti­on and release of the data.
  • In the spe­ci­fic case, it was to be assu­med that the trans­for­ma­ti­on and sur­ren­der costs would be so high that the par­ties would have cho­sen the first opti­on (data access, in the spe­ci­fic case – which can hard­ly be gene­ra­li­zed – for three months; sup­port by the provider):

    In sum­ma­ry, it can thus be sta­ted that, on the basis of the amen­ded G._____ Part­ner Agree­ment, the plain­ti­ff has a con­trac­tu­al right to have its Hand over data at the ter­mi­na­ti­on of the con­tract at your own expen­se. For this pur­po­se, the defen­dant has pro­vi­ded her with three months to enable the data to be trans­fer­red as of the date on which the judgment beco­mes final, by gran­ting it, at the applicant’s expen­se, the appro­pria­te Access gran­ted to the data (e.g. in show mode; the infor­ma­ti­on must be direct­ly elec­tro­ni­cal­ly pro­cessa­ble) and – as far as neces­sa­ry – to Sup­port per­forms, all this at the con­trac­tu­al con­di­ti­ons and system tech­ni­cal con­di­ti­ons valid at the time of ter­mi­na­ti­on of the con­tract.. On the other hand, the plain­ti­ff does not have the right to a trans­for­ma­ti­on of the data with sub­se­quent sur­ren­der on a data carrier.

On the dele­ti­on claim:

Regar­ding the cla­im for can­cel­la­ti­on, the HGer:

  • The Con­tract is not incom­ple­te with regard to the cla­im for dele­ti­on, becau­se its inter­pre­ta­ti­on shows that the­re is no cla­im for dele­ti­on. The HGer ZH deri­ves this from the fact that the rights and obli­ga­ti­ons of the par­ties in con­nec­tion with trans­mit­ted data should also app­ly after ter­mi­na­ti­on of the con­tract; con­se­quent­ly, the­re must be data that remains with the respec­ti­ve counterparty.
  • Data pro­tec­tion the­re is no cla­im for dele­ti­on becau­se the con­tin­ued sto­rage of the data by the pro­vi­der is not unlawful, at least for the time being – until it is cla­ri­fi­ed whe­ther the plain­ti­ff wants to hand over the data.

On the cla­im for accountability:

Regar­ding the right to accoun­ta­bi­li­ty, the HGer:

  • A con­trac­tu­al basis for a cla­im for accoun­ta­bi­li­ty does not exist. Art. 400 para. 1 CO is neither direct­ly nor ana­log­ous­ly appli­ca­ble. In par­ti­cu­lar, the con­tract is not incom­ple­te in this respect becau­se the par­ties did not agree on any obli­ga­ti­on to account for access to the data by means of access logs or reports or with the assi­stance of an SAP expert within the scope of the data secu­ri­ty pro­vi­si­on, which is to be under­s­tood as con­clu­si­ve in the spe­ci­fic case.
  • Also data pro­tec­tion accoun­ta­bi­li­ty is not owed. Art. 15 DPA does not pro­vi­de for a cor­re­spon­ding obli­ga­ti­on, and it is que­stionable (but can be left open in the spe­ci­fic case) whe­ther Art. 8 DPA (right to infor­ma­ti­on) con­fers a cor­re­spon­ding right.