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In its first leading judgment (decision of November 18, 2024, docket no.: VI ZR 10/24)
the German Federal Court of Justice (BGH) dealt with claims for non-material damages pursuant to Art
a proven loss of control or well-founded fear of misuse of the scraped data by third parties is sufficient to establish non-material damage
The BGH therefore bases its interpretation of the concept of damages on the case law of the CJEU
but does not provide a clear definition and leaves many questions unanswered
discuss this judgment and offer insights for organizations and platforms on what to expect in the future
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and welcome to today's episode of our Reed Smith Tech Law Talks podcast
we'll discuss the recent decision of the German Federal Court of Justice
on compensation payments following a data breach or data scraping
I'm partner at Reed Smith's Munich office in the Emerging Technologies Department
And I'm here today with Hannah von Wickede from our Frankfurt office
Hannah is also a specialist in data protection and data litigation
also from the emerging technologies team and tech litigator
Thanks for taking the time and diving a bit into this breathtaking case law
Just to catch everyone up and bring everyone on the same speed
it was a case decided by the German highest civil court
in an action brought by a user of a social platform who wanted damages after his personal data was scraped by a hacker from that social media network
And that was done through using the telephone number or trying out any kind of numbers through a technical fault probably
the hackers could download a couple of million data sets from users of that platform
And the user then started an action before the civil court claiming for damages
And this case was then referred to the highest court in Germany because of the legal difficulties
do you want to briefly summarize the main legal findings and outcomes of this decision?
the FCJ provided its own definition of what a non-material damage under Article 82 GDPR is
They are saying that mere loss of control can constitute a non-material damage under Article 82 GDPR
And if such a loss of the plaintiffs is not verifiable
that also justified fear of personal data being misused can constitute a non-material damage under GDPR
So both is pretty much in line with what the ECJ already has said about non-material damages in the past
the FCJ makes also a statement regarding the amount of compensation for non-material damages following from scraping incident
And this is quite interesting because according to the FCJ
the amount of the claim for damages in such cases is around 100 euros
FCJ also says both loss of control and reasonable apprehension
must first be proven by the plaintiff.
Andy: So we have an immaterial damage that's important for everyone to know
And the legal basis for the damage claim is Article 82 of the General Data Protection Regulation
there was some ECJ case law in the past on similar cases
can you give us a brief summary on what these rulings were about
does the FCJ bring new aspects to these cases
Or is it very much in line with the European Court of Justice that already?
So there was a little clarification in this regard
it's been unclear whether the loss of control itself constitutes the damage or whether the loss of control is a mere negative consequence that may constitute non-material damage
So now the Federal Court of Justice ruled that the mere loss of control constitutes the direct damage
So there's no need for any particular fear or anxiety to be present for a claim to exist.
So we read a bit in the press after the decision
It stays very close to what the European Court of Justice said already
And I would have hoped FCJ provides some more clarity or guidance on what they mean
What does the court say or how can we interpret that?
discussion will most likely tend to focus on what actually constitutes a loss of control
So the FCJ does not provide any guidance here
it can already be said the plaintiff must have had the control over his data to actually lose it
So whether this is the case is particularly questionable if the actual scrape data was public
like in a lot of cases where we have in Germany right here
and or if the data was already included in other leaks
or the plaintiff published the data on another platform
maybe on his website or another social network where the data was freely accessible
it will probably depend on the individual case if there was actually a loss of control or not
And we'll just have to wait on more judgments in Germany or in Europe to define loss of control in more detail.
I think that's also a very important aspect of this case that was decided here
that the major cornerstones of the claim were established
So it was undisputed that the claimant was a user of the network
It was undisputed that the scraping took place
It was undisputed that the user's data was affected part of the scraping
And then also the user's data was found in the dark web
it means that the parties did not dispute about it and the court could base their legal reasoning on these facts
Often you perhaps you don't even know that the claimant is user of that network
There's always dispute or often dispute around whether or not a scraping or a data breach took place or not
It's also not always the case that data is found in the dark web
is not like a written criteria of the loss of control
I think it definitely is an aspect for the courts to say
there was loss of control because we see that the data was uncontrolled in the dark web
I don't know if any of you have views on this
the data in the dark web is from this social platform
users are affected by multiple data breaches or scrapings
and then it's not possible to make this causal link between one specific scraping or data breach and then data being found somewhere in the web
that this could be an important aspect in the future when courts determine the loss of control
because it was already mentioned that the plaintiffs must first prove that there is a causal damage
And a lot of the plaintiffs are using various databases that list such alleged breaches
and the plaintiffs always claim that this would indicate such a causal link
this is now a decisive point the courts have to handle
Before you get to the damage and before you can decide if there was a damage
you have to prove if the plaintiff even was affected
that's a challenge and not easy in practice because there's also a lot of case law already about these databases or on those databases that there might not be sufficient proof for the plaintiffs being affected by alleged data breaches or leaks.
So let's see what's happening also in other countries
So other countries in Europe will have to deal with the same topics
We cannot come up with our German requirements or interpretation of immaterial damages that are rather narrow
any other indications you see from the European angle that we need to have in mind?
And yet first it is important that this concept of immaterial damage is EU law
the ECJ has always interpreted this damage very broadly
And does also not consider a threshold to be necessary
And I agree with you that it is difficult to set such low requirements for the concept of damage and at the same time not demand materiality or a threshold
the Federal Court of Justice should perhaps have made a submission here to the ECJ after all because it is not clear what loss of control is
this contributes a lot to legal insecurity for a lot of companies.
the first takeaway for us definitely is loss of control
other interesting sentences or thoughts we see in the FCJ decision
And one aspect I see or I saw is right at the beginning where the FCJ merges together two events
The scraping and then a noncompliance with data access requests
And that was based in that case on contract
So those three events are kind of like merged together as one event
which in my view doesn't make so much sense because they're separated from the event
and also then from the damages from a non-compliance with an Article 15
I think it's much more difficult to argue with a damage loss of control than with a scraping or a data breach
That that's not a major aspect of the decision but I think it was an interesting finding
that you saw in the decision worth mentioning here for our audience?
Johannes: Yeah so I think discussion in Germany was really broadly so i think just just maybe two points have been neglected in the discussion so far
the court stated that data controllers are not obliged to provide information about unknown recipients
controllers often do not know who the scrapers are
So there's no obligation for them to provide any names of scrapers they don't know
That clarification is really helpful in possible litigation
it's somewhat lost in the discussion that the damages of the 100 euros only come into consideration if the phone number
the claim for damages can or must even be significantly lower.
but also other aspects in this decision that's worth mentioning and reading if you have the time
you're involved in some similar litigation as well
What's happening to those litigation cases in the future
Will we still have law firms suing after social platforms or suing for consumers after social platforms
Or do we expect any changes in that?
you always have to consider the business side
So I think the ruling will likely put an end to the mass GDPR litigation as we know it in the past
the plaintiffs have mostly appeared just with a legal expenses insurer
So the damages were up to like 5,000 euros and other claims have been asserted
So the value in dispute could be pushed to the edge
So it was like maybe around 20,000 euros in the end
But now it's clear that the potential damages in such scraping structures are more likely to be in the double-digit numbers
the legal expenses insurers will no longer fund their claims for 5,000 euros
the vast majority of legal expenses insurers have agreed to a deductible of more than 100 euros
So the potential outcome and the risk of litigation are therefore disproportionate
the plaintiffs will probably refrain from filing such lawsuits in the future.
So good news for all insurers in the audience or better watch out for requests for coverage of litigation and see if not the values in this cube are much too high
So we will probably see less of insurance coverage cases
we expect the same amount or perhaps even more litigation because the number as such
seems certainly attractive for users as a so-called low-hanging fruit
what is your recommendation or your takeaways to platforms
any organization handling data can be affected by data scraping or a data breach
So what is your recommendation or first thoughts
How can those organizations get ready or ideally even avoid such litigation?
it is very important to clarify that the FCJ judgment is ruled on a specific case in which non-public data was made available to the public as a result of a proven breach of data protection
So you should avoid simply apply this decision to every other case like a template because if other requirements following from the GDPR are missing
platforms companies have to consider what they publish about their security vulnerabilities and take the best possible precautions to ensure that data is not published on the dark web
companies can transfer the risk of publication to the user simply by adjusting their general terms and conditions.
These are interesting aspects and I see a little bit of conflict between the breach notification obligations under Article 33
And thank you very much to our audience for listening in
This was today's episode of our EU Reed Smith Tech Law Talks podcast
Please leave feedback and comments in the comments fields or send us an email
We hope to welcome you soon to our next episode
Outro: Tech Law Talks is a Reed Smith production
Our producers are Ali McCardell and Shannon Ryan
For more information about Reed Smith's emerging technologies practice
Disclaimer: This podcast is provided for educational purposes
It does not constitute legal advice and is not intended to establish an attorney-client relationship
nor is it intended to suggest or establish standards of care applicable to particular lawyers in any given situation
Prior results do not guarantee a similar outcome
or comments made by any external guest speaker are not to be attributed to Reed Smith LLP or its individual lawyers.
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Thibault Spirlet is a human rights freelance journalist based in London whose work has been published in the Daily Express
Victoria Tsvetkova burst into tears when she heard her asylum claim was denied in January.
fled Russia in the early days of Vladimir Putin’s full-scale invasion of Ukraine in February 2022 with her girlfriend Anna
They applied for asylum in Finland in April 2022.
the Finnish immigration authorities denied her claim
finding that she and her partner were not “at a risk of serious violations of rights” because they did not openly express their sexual orientation in Russia in the past.
“I cried a lot in front of the police officers because being told that in my face was more than I could handle — it was really awful,” Tsvetkova told The Parliament
She appealed the decision in January and is expecting a decision by the summer.
Tsvetkova told the Finnish authorities that she and Anna did not have the right to get married
live together or have children through IVF or adoption in Russia
suicidal thoughts and panic attacks.
She argued that, as a private children’s tutor, she also risked being fined or even jailed if she ever revealed her sexual orientation to her employer, since Russia’s ban on ‘gay propaganda,’ expanded in late 2022
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Despite the hostilities between Russia and the EU, most borders remain open and asylum seekers are still able physically to travel to Europe, so long as they can obtain a visa. Finland has closed its land border with Russia and certain ports
Russia’s land borders with other EU countries remain open.
I cried a lot in front of the police officers because being told that in my face was more than I could handle — it was really awful
said the agency does not isolate data on LGBTQ+ asylum applicants as EU member states are not required to provide such information.
a Russian lesbian couple from Yekaterinburg
applied for asylum together in Germany last year.
flying to Armenia and Turkey before crossing the Balkans
where local authorities stopped them.
Instead of seeking asylum in the capital Zagreb
they continued their journey on foot towards Germany.
Germany’s immigration services did not recognise them as partners. And while Bykova’s prior asylum claim is still pending in France, Argunova may be sent back to Croatia in accordance with the EU’s Dublin Convention
which states that asylum seekers must file their claim in the first EU country in which they arrive
The two women are living in temporary refugee accommodation in the town of Wickede
and are appealing the rejection decision in a German court
they could face their biggest fear — being separated.
it traumatises you even more because when we finally reached Germany
We wanted to integrate and then we were placed in a camp,” Bykova told The Parliament
LGBTQ+ people fleeing persecution in Russia struggle to obtain the required documentation to support their asylum claims
such as evidence of persecution or membership in the LGBTQ+ community
according to Evelina Chayka of the European Queer Alliance of PostOst Community
Chayka says such cases stem from discrimination and stringent asylum policies in some EU countries that may not fully recognise persecution based on sexual orientation or gender identity as grounds for asylum.
For those whose asylum claims are being processed
obtaining refugee status can take up to 21 months while waiting in deplorable conditions in camps without guidance
founder and board member of Dutch non-profit LGBT World Beside.
The organisation recorded five cases of suicide among Russian-speaking LGBTQ+ asylum seekers staying in Dutch camps in just one year
“The number of suicide rates is really high,” van Hayzer said.
a 28-year-old gay Russian asylum seeker supported by the organisation
says he developed suicidal thoughts while waiting in a refugee camp in the Netherlands
He finds it “absolutely not surprising” that people would want to take their own lives in such circumstances.
“I see how people are degrading here — they start using drugs
drinking alcohol because waiting for months
without knowing when the process will end is mentally challenging,” he told The Parliament.
Kataev has been invited to only one interview since he filed his asylum application in May 2023
he doesn’t know when the second interview will take place
He started taking antidepressants to cope with the wait
his boyfriend will join him from Georgia on a fiancé visa.
“I don’t want to put him through what I’ve been through,” he said.
found a widespread lack of safety among asylum seekers in the Netherlands' immigration system
with more than half reporting feeling unsafe and three-quarters reporting going “back into the closet,” or concealing their sexual orientation.
The three couples The Parliament spoke to all said that going back to Russia now is not an option.
it has taken aim specifically at LGBTQ+ rights: besides the expansion of the ‘gay propaganda’ ban
the government has banned sex reassignment surgery and hormonal therapy
while classifying the “international LGBT movement” as an “extremist organisation.”
Tsvetkova is hoping that these changes will bolster her appeal in Finland
anyone taking part in or financing an LGBTQ+ organisation is punishable by up to 12 years in prison
Both she and her partner Anna are now volunteering at the LGBTQ+ EQUAL PostOst organisation
which she says means they could be sentenced upon their return to Russia.
she says they would either apply for asylum in other European countries or the United States
“We’d have to leave the Schengen area and go somewhere — probably Turkey — because we Russians don’t need a visa there
we don’t have any money or any other emergency fund.”
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A "glitch" in the Information Technology and videogame world refers to a system error that has no negative impact whatsoever on performance
it is not uncommon for users to turn a glitch to their advantage
The essence of Caroline Kryzecki's (Wickede/Ruhr, Germany 1979) work
currently on show at Madrid's Bernal Espacio Gallery in her first ever solo exhibition in Spain
That unforeseen error whose ocurrence only reinforces the fact that human nature is present.
The exhibition comprises a collection of works on paper of various sizes (50 x 35 cm
100 x 70 cm or 200 x 152 cm) in which the image is achieved using only horizontal or vertical lines and is based on a motif of repetition
These works are closely linked to the digital world by their automated appearance
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Like when some discordant note in a dream makes us aware that we have just dreamed
those little mistakes in the drawing are what make us realise that what we are looking at is
totally analogous and hand-drawn with pens
KSZ 200/152-06 Courtesy of: Sexauer Gallery
Kryzecki's methodology manages to stop time in its tracks
not just for the patently laborious determination to find her own language
but also because she is radically opposed to what modern society demands of us
In a world of fast and fleeting consumerism
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She alone has access to an algorithmic system made up of patterns of repetition
possess a huge power of attraction as much for their aesthetic beauty as for their ability to depict infinite horizons and to hint at realities beyond mere lines on a page
The works require close inspection and dedication although
The work is the representation of Kryzecky's interpretation of the parameters of her environment for which she needs to establish structures and to order the chaos of what is considered "normal"
It's an intimate and delicate work that transports us into its universe
KSZ 100/70-11 Courtesy of: Sexauer Gallery
Caroline Kryzecky's work has as a starting point an archive of the pictures she has compiled
the decorative images we see around us in our day-to-day lives
These references have always been present in her work
linked to geometry in both her more abstract paintings and in others less so where the lines were always accompanied by figuration
Without following pre-established parameters
her trajectory sometimes involved experimentation with objects or sculpture-like pieces
But her art took a different and deliberate turn when she started a residency in Istambul in 2010
arriving with absolutely none of her previous working materials or media at all
This was a voluntary gesture of closure that enabled her to discover a language with which to best express herself
red and green are the colours she uses in her works - those being the four basic ballpoint colours - and she limits herself to the paper dimensions mentioned above
This self-imposed restriction has favoured the creation of her own personal code and has opened the way to the possibility of an infinite variety of combinations
this has served to expand her creative potential
In the same way that "error" became a powerful element in her work
she has been able to turn limitations into her greatest freedom
View of the exhibition. Courtesy of: Bernal Espacio Gallery
Demonstrating emphatically a divergence from other artforms based on shortcuts, she engages directly with each piece, tending and refining it until a language is obtained that needs no illustrations
whilst producing the most abstract and poetic version of the work. On entering the exhibition, visitors find themselves surrounded by the beauty of slow movement and transported to a lucid dream of infinite worlds.
(Translated from the Spanish by Shauna Devlin)
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