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Reference / The SignalSweden · Updated 19 Sep 2026
The Signal

The month runs from the request, not from the right inbox

A reprimand where a request sent to an address other than the designated one fell outside the internal routine and was answered more than five months later.

31 Mar 2021DecisionSwedenReviewed 15 Sep 2026

By Magdalena Góralczyk, Partner, Head of Data Protection.

What happened

The authority found that Klarna Bank AB had processed personal data contrary to Article 12(3) by not meeting an access request without undue delay, and issued a reprimand under Article 58(2)(b). The request arrived by email on 5 Jan 2019 at an address other than the one the company points to for data protection matters, so it was not handled under the company's internal routine; the information and the copy were sent on 18 Jun 2019, more than five months after the first request, and the requester was not informed of the delay. The authority held that the company handling a large number of requests, and answering follow up questions promptly, did not change that assessment. On a second complaint it found no breach, the request there having been met within a fortnight, with the company asking for an alternative address once told the answer had not arrived.

What changes at the desk

Any address you publish is an address a request can arrive at, and the month starts when it does rather than when it reaches the team that handles these. Route anything that reads like a request into one queue on the day it lands, whichever mailbox took it. If you are going to need the extension, claim it inside the first month and give the reason, because it cannot be claimed afterwards, and volume is not on its own a reason an authority will accept.

Primary source

DecisionSweden31 Mar 2021

Elsewhere on the record

Entries from the same jurisdiction, or on the same kind of document. Each one links the text it was written from, as this one does.