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On 31 May 2023, the Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) issued a fine of EUR 300'000 against a bank for lack of transparency regarding an automated rejection in its credit card application system. Despite the customer having a good credit score and a regular high income, the bank only offered general information about the scoring process, failing to provide specific details about why the customer's application was rejected. According to the BInBDI, this constituted a lack of transparency which hindered the customer's ability to effectively challenge the automated decision. As a result, the customer filed a complaint with the BlnBDI. The BlnBDI determined that the bank violated specific articles of the General Data Protection Regulation (GDPR) requiring transparency and the right not to be subject to automated decision-making or profiling. The bank acknowledged its violation, implemented changes to its processes, and pledged further improvements, which contributed to a reduction in the imposed fine.
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