A clear photo of the affected passengers holding their ID next to their face
Jul 9, 2019, 3:49 pm
#91
Join Date: Apr 2008
Location: Gdynia, Poland
Posts: 631
What I don't understand is, why LH refuses to accept other methods of verification. My wife submitted EU261 claim due to cancelled flight. They accepted the claim but asked for the photo, which is reason of this discussion. As my wife is in Germany at the moment, we offered that she would visit one of LH's offices there in order to let them verify her identity. Such method seems to be much more reliable than verification on basis of photo and, what's equally important, doesn't give any reasons to be afraid of identity theft. Unfortunately, they refused because they have to act according to the new policy. I don't see any logic in it.
Last edited by tropikey; Jul 9, 2019 at 10:43 pm
Jul 10, 2019, 4:59 am
#92
Join Date: Nov 2012
Location: Rhineland-Palatinate
Programs: *A Gold (A3), HHonor Gold
Posts: 5,691
I sent the following email as a reply to both Customer Relations and to the following e-mail:
Group Data Protection Officer for the Lufthansa Group
Dr. Barbara Kirchberg-Lennartz
E-Mail: [email protected]
Group Data Protection Officer for the Lufthansa Group
Dr. Barbara Kirchberg-Lennartz
E-Mail: [email protected]
Sir/Madam and Dr. Barbara Kirchberg-Lennartz,
Your request to provide a picture of my face while holding my ID has several issues:
- There is no explanation of the lawful basis used for such a request (Article 6.1 of GDPR)
- There are no information about where this personal data will be stored, for how long and no explanation about my rights to correct, access or delete it and more , as detailed in Article 13 of the GDPR
- There was no provision in the Terms and Conditions of the booking made with Lufthansa that I should provide such information in case of financial claim following EC261 regulations.
- I consider this request disproportionate compared to the goal, as it is a possible source for identity theft.
Following those, I refuse to provide this information without further detailed explanation. I consider this should not block or slow my request for compensation as outlined in case Feedback ID XYZ. I will provide the booking confirmation and boarding pass separately using the feedback form.
Best regards,
Your request to provide a picture of my face while holding my ID has several issues:
- There is no explanation of the lawful basis used for such a request (Article 6.1 of GDPR)
- There are no information about where this personal data will be stored, for how long and no explanation about my rights to correct, access or delete it and more , as detailed in Article 13 of the GDPR
- There was no provision in the Terms and Conditions of the booking made with Lufthansa that I should provide such information in case of financial claim following EC261 regulations.
- I consider this request disproportionate compared to the goal, as it is a possible source for identity theft.
Following those, I refuse to provide this information without further detailed explanation. I consider this should not block or slow my request for compensation as outlined in case Feedback ID XYZ. I will provide the booking confirmation and boarding pass separately using the feedback form.
Best regards,
Jul 10, 2019, 2:15 pm
#93
Join Date: Sep 2013
Posts: 2,188
What I don't understand is, why LH refuses to accept other methods of verification. My wife submitted EU261 claim due to cancelled flight. They accepted the claim but asked for the photo, which is reason of this discussion. As my wife is in Germany at the moment, we offered that she would visit one of LH's offices there in order to let them verify her identity. Such method seems to be much more reliable than verification on basis of photo and, what's equally important, doesn't give any reasons to be afraid of identity theft. Unfortunately, they refused because they have to act according to the new policy. I don't see any logic in it.
I have yet to experience the request myself but I won't be happy when/if it happens to me.
Jul 11, 2019, 2:13 am
#94
Join Date: Nov 2012
Location: Rhineland-Palatinate
Programs: *A Gold (A3), HHonor Gold
Posts: 5,691
I sent the following email as a reply to both Customer Relations and to the following e-mail:
Group Data Protection Officer for the Lufthansa Group
Dr. Barbara Kirchberg-Lennartz
E-Mail: [email protected]
Group Data Protection Officer for the Lufthansa Group
Dr. Barbara Kirchberg-Lennartz
E-Mail: [email protected]
thank you for your e-mail. We have forwarded your e-mail to the Customer Relations department and you will receive an answer from there.
Kind regards
Deutsche Lufthansa AG
Group Data Protection
Kind regards
Deutsche Lufthansa AG
Group Data Protection
Jul 11, 2019, 9:31 am
#95
Original Poster
Join Date: Aug 2005
Programs: UA*G(1K), PC Diamond Amb, Marriott Titanium, Accor Platinum
Posts: 4,671
I am not sure whether it is purely technical to have all conversations in their CRM software and the DPO will properly answer from CR or if she basically is saying "I do not care". I give them a month to answer and process the EC261 request. If not then I will contact the Rheinland Pfalz DPO.
HTB.
Jul 13, 2019, 12:45 pm
#96
Join Date: Mar 2018
Posts: 142
However, you can usually get around it by explaining why it's not necessary for compliance before telling them to do one if you have any cojones.
Jul 13, 2019, 6:18 pm
#97
Original Poster
Join Date: Aug 2005
Programs: UA*G(1K), PC Diamond Amb, Marriott Titanium, Accor Platinum
Posts: 4,671
HTB.
Jul 14, 2019, 3:18 am
#98
Join Date: Nov 2012
Location: Rhineland-Palatinate
Programs: *A Gold (A3), HHonor Gold
Posts: 5,691
Which industries and where ? The postID thing in Germany is different as it actually is secure (somewhat).
Jul 14, 2019, 5:27 am
#99
Join Date: Mar 2018
Posts: 142
It's trivial to avoid if you have any spine.
Jul 14, 2019, 9:45 am
#100
Original Poster
Join Date: Aug 2005
Programs: UA*G(1K), PC Diamond Amb, Marriott Titanium, Accor Platinum
Posts: 4,671
No need to become personal. So how would you do this? The difference here is that the customer service department has absolutely no interest in doing business with customers who want money back.
HTB.
Jul 14, 2019, 10:27 am
#102
Join Date: Mar 2018
Posts: 142
However, many many business work with money laundering regs and probably just as many have to be aware of when their clients are PEPs. I wouldn't necessarily exclude airlines based upon what I've said.
You asked me for a paraphrasing so I simply gave one. There was nothing personal nor was it directed at anyone and especially not you.
I already explained how to do it in my other post.
(Why do you think that's different from any other situation where you're asked for verification like this?)
Jul 14, 2019, 10:31 am
#103
Join Date: Mar 2018
Posts: 142
Jul 14, 2019, 12:42 pm
#104
Join Date: Nov 2012
Location: Rhineland-Palatinate
Programs: *A Gold (A3), HHonor Gold
Posts: 5,691
Really, could you please post the ICO conclusions pertaining to Lufthansa asking this for a reimbursement or paiement of compensation in an automatic email without any link to the DPO or information about goals, storage, etc .... ?