Lufthansa finally sent me the history (change log) portion of my PNR data but continues to claim that it isn’t responsible for either its retail agent Vayama.com (who created the PNR as an agent of Lufthansa) or the wholesale consolidator Transam Travel (who issue the ticket as an agent of Lufthansa). The LDI-NRW upheld Lufthansa’s false claim that it has no control over its agents, and is not responsible for their actions. this is both legally and factually incorrect, and leads me to suspect that the LDI-NRW beleived whatever Lufthansa said without conducting an independent investigation of the facts or reviewing Lufthansa’s „agency appointment agreements“ with Vayama.com and Transam Travel. The LDI-NRW also upheld Lufthansa’s disclosure only of general categories of potential third-party recipients of my data in other countries, even though that response showed that my data could have been illegally transferred to countries without adequate data protection regimes. I am disappointed in the complete failure of the LDI-NRW to fulfill its responsibilities. My only further recourse is to bring a lawsuit against Lufthansa in German court. if anyone can offer pro bono legal assistance for that purpose, please contact me. (the whole history on hasbrouck.org)
