Overview
- In October the Wiesbaden credit bureau began sending personal postal access codes to people who already asked for an Article 15 GDPR copy so they can retrieve archived records online.
- The new archival disclosure is delivered as a two‑part data copy: one part shows earlier data snapshots and the other lists the exact information used for past score calculations including the querying company and the scoring model.
- Schufa says the archived files are kept for legal documentation and to check and improve scoring models and that these historical records do not change current credit reports or present score values.
- Privacy group NOYB continues to press legal claims over long retention of historical data while Germany’s new transparency rule for automated credit scoring (BDSG §37a) takes effect on November 20, 2026.
- Consumers must explicitly ask for archived data under Article 15 GDPR, can expect a response within about one month or up to three months for complex cases, and Schufa plans a broader redesign of its consumer disclosures in 2027.