Direct answer · GDPR
Explaining an automated decision and trade secrets
No, not entirely. The data subject has the right to meaningful information about the logic involved in an automated decision (Article 15(1)(h)). According to the Court of Justice in Dun & Bradstreet Austria, the organisation must explain the procedure and principles actually applied in such a way that the data subject understands how his or her personal data led to the result. If it considers that trade secrets or data of others are at stake, it submits that information to the supervisory authority or the court, which weighs how much access the data subject receives.
For you to establish
- Which information does the organisation want to withhold, and why?
Articles
- Art. 15(1)(h) GDPR Right to meaningful information about the logic involved.
- Art. 15(4) GDPR The right to obtain a copy must not adversely affect the rights and freedoms of others.
Case law
- Dun & Bradstreet Austria (CJEU, C-203/22, ECLI:EU:C:2025:117, 2025-02-27)Operative part: explanation of the procedure actually applied; where trade secrets are involved, the supervisory authority or court weighs the interests.
Guidelines and decisions
- Guidelines 01/2022 on data subject rights - Right of access (EDPB, v2.1, 2023-03-28)Guidelines on the right of access.
Read the article Check your own case General interpretation, not legal advice. The official source remains authoritative.
