Case study 7: Allianz requesting excessive personal information at quotation stage [2011] IEDPC 7 (2011)

Case study 7: Allianz requesting excessive personal information at quotation stage [2011] IEDPC 7 (2011)

Allianz's collection of date of birth, mother's maiden name, and place of birth at the quotation stage was excessive and not required under the Data Protection Acts. Suggesting otherwise was false and misleading. Security requirements could be met by less intrusive means, such as using a quote reference number.

Citation
[2011] IEDPC 7
Parties
Complainant: Complainant (individual); Respondent: Allianz
Jurisdiction
Ireland
Procedural Posture
Data Protection Complaint / Decision by Data Protection Commission
Outcome
Complaint upheld
Legal Topics
Excessive Data Collection, Misrepresentation of Legal Requirements, Security of Personal Data
Data Protection Privacy Law Excessive Data Collection Misrepresentation of Legal Requirements Security of Personal Data

Case Brief

Summary, issues, holding and outcome

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Parties

Complainant (individual)

Complainant

Allianz

Respondent

Procedural Posture

Data Protection Complaint / Decision by Data Protection Commission

Legal Issues

  1. 1 Whether Allianz requested excessive personal information at the quotation stage in breach of the Data Protection Acts
  2. 2 Whether Allianz misrepresented the requirements of the Data Protection Acts to customers

Ratio Decidendi

Allianz's collection of date of birth, mother's maiden name, and place of birth at the quotation stage was excessive and not required under the Data Protection Acts. Suggesting otherwise was false and misleading. Security requirements could be met by less intrusive means, such as using a quote reference number.

Court Disposition

Complaint upheld

Orders

  • Allianz to cease using ID verification screen at quotation stage
  • Allianz not to seek date of birth, mother's maiden name, or place of birth at quotation stage in future