Groupon Ireland Operations Limited

Background to the Complaint 1. On 11 June 2018, the Complainant contacted Groupon by email requesting access to their personal data and the subsequent erasure of those personal data. The Complainant sent this email to a number of different channels within Groupon. The Complainant also telephoned Groupon on 13 and 14 June 2018 in relation to their access and erasure requests. 2. In response, the Complainant was directed to submit their requests via Groupon’s online portal, which required the Complainant to upload a copy of an ID document in order to verify their identity. 3. The Complainant considered this requirement to be excessive and an obstacle to the exercise of their rights. The Complainant also noted that no such requirements were in place in order to register or create an account with Groupon. Accordingly, on 19 June 2018, the Complainant submitted a Complaint to the BW DPA. The Complaint at this point was solely in relation to the Complainant’s concerns about being asked to upload a copy of an ID document. In the circumstances where the DPC was deemed to be the competent authority for the purpose of Article 56(1) GDPR, the BW DPA subsequently transferred the Complaint to the DPC. Complaint Handling and Investigation by the DPC 4. On 1 February 2019, the DPC wrote to Groupon formally commencing its investigation and requesting that Groupon address the concerns raised. 5.