01
Factual background & dispute
- SCHUFA automatically calculated credit probability values based on personal data.
- Third parties, including banks, relied on these scores when establishing, executing, or terminating contracts.
02
Core issues & judicial focus
- When scoring activities constitute automated individual decision-making
- What explanations and rights safeguards must be provided to data subjects
03
Judicial finding & holding
- The court confirmed that scoring falls under the rules on automated individual decision-making when it plays a decisive role in third-party decisions.
- Such processing requires a valid legal basis and appropriate safeguards for data subjects' rights.
04
Practical risk implications
01Enterprises must verify the actual weight assigned to model scores in final decisions.
02High-impact automated decisions require human intervention mechanisms, objection procedures, and explanatory documentation.
03Model inputs, outputs, thresholds, and human review records must remain traceable.