cross-posted from: https://links.hackliberty.org/post/435505

A data controller responded to a #GDPR request under art.15 & 17 (thus, an access request coupled with erasure request). They responded with a refusal, demanding ID card. They probably demanded it be in color, but I responded with a black and white copy of my ID. They refused again, affirming that the ID card must be in color. So then I sent them a color copy, but I used black boxes to redact my facial image and all personal text except my name. They again refused to honor my request, saying “zonder vlekken en met een goede resolutie om te worden geaccepteerd”. That translates into “without spots or stains”, correct? I don’t think that means without redactions.

Anyway, I would like a GDPR expert to confirm or deny whether the controller’s refusal and demands are lawful.

The relevant GDPR text is:

• https://gdpr-text.com/read/recital-64/
• https://gdpr-text.com/read/article-12/#para_gdpr-a-12_6

My request (via post) included my residential address and also mentioned a unique email address that only that controller knows me by (though they would not necessarily know it’s unique). Shouldn’t that be sufficient?

UPDATE

This abstract covers some of my questions. Indeed redactions on the ID card are allowed when making requests.