Authority requests a psychological assessment - what about data protection?
The following situation is the basis:
The driver's license authority responsible for me expresses doubts about my suitability to drive motor vehicles due to a drunk driving incident and therefore demands the submission of a corresponding medical-psychological assessment.
This demand is based on § 46 (3) in conjunction with § 13 No. 2 b of the Driver's License Regulation and is also lawful.
The assessment should "bottom line" determine whether the driver's license holder will drive a motor vehicle under the influence of alcohol in the future or whether impairments as a result of uncontrolled alcohol consumption exist, which call into question the ability to drive a motor vehicle, etc.
The result of my assessment was positive.
Now, the driver's license authority demands the submission of the complete assessment. However, the assessment contains - beyond the final result that is of interest to the driver's license authority - many other very personal statements, life circumstances, and the presentation of personal problems, etc.
The requirement for the complete assessment is often justified by driver's license authorities with the need to check the assessment for completeness or any inconsistencies.
In my opinion, this argument is by no means sufficient. On one hand, the assessment is supposed to be prepared by experts, which is why the subjects, as the clients of the assessment, must also consult appropriately authorized assessors. On the other hand, a civil servant at the driver's license authority is then supposed to review a SPECIALIZED ASSESSMENT for errors.
However, such a civil servant certainly does not have the appropriate expertise to interpret any details beyond the result of the assessment that may be relevant to the driver's license authority. Ultimately, only the result of the assessment should be of interest to the driver's license authority.
As far as I can judge as a layperson, I therefore consider it questionable in terms of data protection that such an assessment, equipped with sensitive data, ends up in the hands of someone who cannot make use of these detailed data.
My final question:
Can the driver's license authority really request the complete assessment with all personal data?
In this case, should the driver's license authority not, for data protection reasons, be satisfied with the answer to the actual core question provided by the assessing authority?
