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What Must a Latvian Credit Bureau Do Before Disclosing Individual Data?

Latvia's lawful-basis, purpose, source, accuracy, dispute, access-log and special-data controls before a credit bureau discloses individual information.

Created on
Created on 2026-09-13
Reading time
7 minute read
Topic
Latvia law

Short answer

Before a Latvian credit information bureau releases information about an individual, the disclosure must sit inside a licensed bureau activity, go to an eligible user with a written bureau agreement, use only permitted sources, and serve either creditworthiness assessment or the user's own credit-risk management. The requester must have GDPR-compliant consent, a right arising from the customer agreement, or another GDPR condition permitting the processing.

The bureau must also apply the Act's content and data-quality controls: stored information must correspond to what the supplying user provided; a live dispute must remain visible; special-category personal data must not be disclosed to third parties; and one user's identity as the contributor is withheld when the information is supplied to another user. The bureau records the request so that access is auditable and the individual can exercise statutory access rights.

The duties are divided between the bureau and the requester. The does not say that consent is always required or that the bureau alone bears responsibility for proving the requester's legal basis. Section 21 expressly makes the requester responsible for requesting information only where a lawful basis and the statutory purpose exist. The bureau nevertheless remains a data controller subject to the special Act, the GDPR and Latvia's Personal Data Processing Law.

Start with an eligible, contracted recipient

Section 1 defines a credit-information user as an eligible person that has concluded a written agreement with the bureau for supplying or receiving credit information. The eligible classes in Section 5 include traders, certain professional and individual enterprises, cooperatives and specified public bodies when the statutory conditions are met.

A disclosure should therefore not be treated as an anonymous data sale. The recipient must be authenticated against the contracted user, and the request must be attributable to that user. This matters both for lawful access and for the individual's later right to understand who used the bureau to obtain restricted state-system information.

Confirm the statutory purpose

Section 4 limits the ordinary licensed system to two purposes: assessing a customer or prospective customer's creditworthiness, and managing the user's own credit risk. A technically valid user account does not authorize unrelated marketing, employment screening, curiosity searches or open-ended profiling.

The Act states:

Kredītinformācijas lietotājs kredītinformāciju no kredītinformācijas biroja … iegūst un izmanto klienta vai iespējamā klienta kredītspējas vērtēšanai vai sava kredītriska pārvaldībai.

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The bureau's release workflow should capture which of these purposes applies and connect it to the relevant customer or application. That is an operational inference from the purpose limitation, not a separately worded statutory form requirement.

Confirm a lawful basis—but do not assume it must always be consent

Section 18 gives three alternatives. A user may request and receive information when:

  1. the customer or prospective customer has given consent that meets the GDPR standard;
  2. the right to obtain information arises from the customer agreement; or
  3. another GDPR condition permits processing of the individual's data.

The Latvian text is explicit:

Kredītinformācijas lietotājs ir tiesīgs pieprasīt un saņemt kredītinformāciju no kredītinformācijas biroja, ja pastāv kāds no šādiem nosacījumiem.

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Consent is thus one route, not a universal answer. A bureau should require the user to identify and document the route relied on. Section 21(3), however, assigns the user direct responsibility for having requested only where a legal basis and the Act's personal-data purpose exist. The bureau should not rewrite this allocation by representing that it has independently adjudicated every underlying contract.

Check that the source and content are permitted

Section 6 confines the bureau to information from its users, another bureau where legislation allows it, permitted state information systems, and specified EU or EEA foreign sources. Public availability alone does not turn every website, social-media profile or purchased dataset into a lawful credit-information source.

The record must also contain only information the Act permits and remains entitled to retain. Section 12 lists debt fields such as the person's identifying data, initial and current debt amount, first default date, insertion and update dates, repayment or other termination information, the contributing user and its sector, and whether the person disputes the debt or a court dispute exists.

Two disclosure-specific restrictions are especially important. When information supplied by one bureau user is disclosed to another, Section 12(3) requires the bureau not to reveal information identifying the contributing user. Section 12(6) permits limited processing of special-category personal data connected with debt only if those data are not disclosed to third parties.

Apply accuracy and dispute controls

Responsibility is again split. Section 20 makes the bureau responsible for ensuring that its database corresponds to information supplied by the user. Section 21 makes the supplying user responsible for completeness, truthfulness, consistency with the customer agreement and timely updates.

Kredītinformācijas birojs ir atbildīgs par to, lai tā datubāzē iekļautās ziņas atbilstu kredītinformācijas lietotāja sniegtajām ziņām.

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If the individual has made a written objection, Section 22 requires a dispute marker while the matter is examined. A confirmed mismatch or error must be corrected or deleted. The bureau must then promptly inform users to whom it supplied that information during the preceding 12 months. If the supplier rejects a debt objection and the individual maintains it, the continuing objection must remain marked. A pre-disclosure check should therefore ensure that the report does not silently present disputed information as uncontested.

Preserve an access trail and support the individual's rights

Section 16(2) requires the bureau to retain information about a user's request for one year, although the legislation governing a restricted-access state system may prescribe a different period. Section 19 gives the individual the right to obtain information processed about them and information about a user that used the bureau to request and receive state-system data. Online and in-person access is free; postal delivery may carry actual postal costs.

This makes request identity and timestamp part of the compliance record. The individual-facing access right does not mean every report must be proactively sent to the individual before disclosure, but the bureau must be able to account for processing and respond through the statutory channels.

Special rules for state-system and foreign information

Section 13 applies when a user seeks restricted information from a Latvian state information system through the bureau. The user must itself be legally entitled to receive that information, and its request must be lawful. The bureau may use the information only to pass it to that user unchanged and must not store it after transfer. The particular state-system legislation and GDPR may add further duties.

Foreign information received for a Latvian user is subject to a similar unchanged, single-purpose, no-retention rule under Section 14(2). Outbound disclosure to an EU or EEA credit-information intermediary is permitted only if all Section 14(3) conditions are satisfied: consent or another GDPR basis, qualifying end users observing the statutory purpose, and immediate unchanged onward transfer without other use or storage.

A defensible release gate

Read together, the provisions support a practical release gate:

  1. authenticate an eligible user under a live written bureau agreement;
  2. identify the individual and the requester's relationship to them;
  3. record the lawful basis and whether the purpose is creditworthiness assessment or credit-risk management;
  4. confirm that each source, field and retention period is permitted;
  5. preserve repayment, update and dispute information;
  6. suppress contributor identity and any prohibited special-category data;
  7. apply the stricter unchanged-transfer and no-retention rules where state-system or foreign pass-through data are involved; and
  8. log the request for the applicable period and keep it available for access, correction and supervisory review.

This checklist translates the statute into controls. It should be adapted to the exact data source, user and GDPR basis rather than treated as a substitute for them.

MCP source-quality finding

The exact Latvian title search retrieved the current Act uniquely, and full Fetch returned its coherent consolidated text. A broader Latvian query combining disclosure, natural person, consent and contract returned four other laws but omitted the controlling Act even though those concepts appear in its body. That retrieval limitation is already covered by ; no duplicate issue was filed.

Conclusion

A Latvian bureau should disclose an individual's credit information only through a licensed, contracted and auditable relationship, for a statutory credit purpose, on one of Section 18's lawful bases, using permitted and appropriately retained data. It must preserve accuracy and dispute information, protect contributor identity and special-category data, and follow stricter pass-through rules for restricted state-system and foreign information. The requester remains directly responsible for the legality and purpose of its request, so compliance is a shared control rather than a consent box checked by the bureau alone.

Sources

This article provides general legal information, not advice for a specific matter. Laws, facts and procedural deadlines may change the result. Follow the linked primary sources and obtain local advice before acting.