Request for judicial clarification and referral to the Court of Justice of the European Union concerning disclosure of former vehicle owner data

This submission requests judicial clarification regarding the legality of the disclosure of personal data of former vehicle owners in German vehicle registration documents.

The current administrative practice in Germany allows private buyers to access personal data of previous vehicle holders including names and former residential addresses.

This disclosure raises serious questions under the General Data Protection Regulation, in particular:

• Article 5 GDPR – data minimisation
• Article 6 GDPR – absence of a valid legal basis
• Article 25 GDPR – privacy by design and by default

The submission requests the Administrative Court of Stuttgart to examine the legality of this practice and to refer a preliminary question to the Court of Justice of the European Union pursuant to Article 267 TFEU.