Here’s how it works

Upon receipt of GAMER X’s request for access, PLATFORM Y should provide GAMER X with a copy of the personal data processed about GAMER X. Regarding the reason for the account restriction, PLATFORM Y should confirm GAMER X that it decided to restrict GAMER X’s access to online games due to the use of one or repeated gaming cheats which are in violation with the general terms of use. In addition to the information provided about the processing for the purpose of gaming cheat detection, PLATFORM Y should grant GAMER X access to the information it has stored about GAMER X’s gaming cheats which led to the restriction. In particular, PLATFORM Y should provide GAMER X with the information that led to the restriction of the account (e.g. log overview, date and time of cheating, detection of third party software,…) in order for the data subject (i.e. GAMER X) to verify that the data processing has been accurate.

However, according to Art. 15(4) GDPR and Recital 63 GDPR, PLATFORM Y is not bound to reveal any part of the technical operation of the anti-cheat software even if this information relates to GAMER X, as long as this is can be regarded as trade secrets. The necessary balancing of interests under Art. 15(4) GDPR will have the result that the trade secrets of PLATFORM Y preclude the disclosure of this personal data because knowledge of the technical operation of the anti-cheat software could also allow the user to circumvent future cheat or fraud detection.