How can we fight redlining?

City maps about bad debtors: Redlining has now been given a name in Germany: SCHUFA'S PRIVATE DEBT INDEX (PVI)

SCHUFA is now even publishing city maps colored after payment problems for the future.

We had pointed out the problems that city maps cause, in which districts and addresses are presented as crisis-prone as a general rule. Such plans are used by creditors worldwide to reduce their offers or to make them more expensive where they suspect higher default rates. Customers can hardly defend themselves because everyone there does the same and competition is eliminated.

In the English edition of Wikipedia, redlining is described as follows:

"Redlining is the practice of denying certain services such as banking services, insurance, access to jobs, health care or even to supermarkets in areas where people live who are often also ethnically specific. The term originated in the late 1960s in the USA, where banks provided city maps with red lines to demarcate such districts. At that time, it was mainly inner-city areas with a poor (black) majority. "

The SCHUFA is now also coloring areas in red and, despite the criticism we have expressed for years, pretends with innocence that it ultimately only communicates facts and thus offers opportunities to combat over-indebtedness.

Some cities and even the Ministry of Family Affairs seem to respond to this argument and use these figures, for example, to distribute funds for debt counseling.

In fact, these red cards create an image for districts or entire cities such as Berlin and Wilhelmshaven, which are discriminatory and deter investors of all kinds.


SCHUFA receives the data through the approval of the customers of all financial institutions, mail order companies, telephone companies, etc. in the so-called SCHUFA clause, which has already restricted the case law. This stipulates a strict limitation on the use of personal data, according to which SCHUFA "only makes (makes) personal data available if a legitimate interest in this has been credibly demonstrated in individual cases."

The SCHUFA clause for a current account is:

"I consent to the bank transferring data to SCHUFA HOLDING AG, Hagenauer Strasse 44, 65203 Wiesbaden, about the application, opening and termination of this account. Irrespective of this, the SCHUFA bank will also transfer data due to non-contractual behavior (e.g. According to the Federal Data Protection Act, these reports may only be made if this is permissible after weighing up all the interests involved.

In this respect, I also release the bank from banking secrecy. SCHUFA stores and transmits the data to its contractual partners in the EU internal market in order to provide them with information for assessing the creditworthiness of natural persons. SCHUFA's contractual partners are primarily credit institutions as well as credit card and leasing companies. In addition, SCHUFA also provides information to commercial, telecommunications and other companies that provide services and deliveries against credit. SCHUFA only provides personal data if a legitimate interest in it has been credibly demonstrated in individual cases. SCHUFA provides address data to identify debtors. When providing information, SCHUFA can also provide its contractual partners with a probability value calculated from its database for assessing the credit risk (score method).

I can get information from SCHUFA about the stored data concerning me. Further information about the SCHUFA information and score procedure is contained in a leaflet, which is available on request from the SCHUFA contract partner. "


According to data protection, however, it is not personal data if only the district in which the customer lives is marked with his personal data, so that conclusions can only be drawn indirectly about him personally.

Such an interpretation is purely formal and unusual in public law. It is sufficient if the personal data are used beyond the agreed purpose, and that is their use for red maps in any case, in such a way that the customer suffers personal damage. However, this can be assumed in any case if his entire district is in danger of being discriminated against.

The SCHUFA has set up a scientific advisory board, but nothing critical has been heard from it so far. Data protection activists are also not represented there.


Our criticism is not directed against using the SCHUFA data for overindebtedness research. This is necessary and the willingness of SCHUFA to participate here is to be emphasized positively. The fact that SCHUFA pretends to replace this research with its own presentation of results is problematic.

From the point of view of this research, the PVI is scientific nonsense. There is no logical relationship between over-indebtedness and where you live. These are purely statistical correlations that are determined by intervening variables such as unemployment, the accumulation of household types, age structure and income and that mislead local politicians.

The fact that the economy uses such false correlations successfully is due to the fact that, purely profit-oriented, it is not interested in the individual business but in all business as a whole. If she succeeds, for example, in reducing the failure rate by excluding all blonde consumers from an account, this was successful if, statistically, the blondes are more likely to abuse than the black-haired ones. At the same time, the "blondes" jokes are not given statistical consecration by any means.

In fact, in a comparison of Wilhelmshaven and Hamburg, we were able to show that borrowers in some districts with high unemployment pay more punctually than in rich areas that were colored as cheap.


First of all, the concept of the personal debt index is misleading. SCHUFA does not mean debt at all, but over-indebtedness, but does not dare to say this clearly.

For example, the PVI does not reflect the borrowing in Germany, but a card with "negative credit-relevant information". The problem with this isn't that this information doesn't report credit disruptions. The problem is that the SCHUFA combines them with the address and the age, suggesting that people with a certain postcode or a certain age pose problems. In fact, our research in the 2007 Overindebtedness Report shows that a completely different picture emerges if one includes living at home for young people or unemployment or type of housing in residential areas as a characteristic. Then suddenly the residential districts no longer differ in terms of over-indebtedness.

Much is wrong in the details, too, because SCHUFA does not ask for its characteristics according to social scientific criteria but rather receives it from the creditors, who are thus subjectively colored, are used for debt collection and lending and thus seem scientifically rather random. This becomes particularly clear with the so-called "red features", which are all of a bureaucratic nature and only indirectly have something to do with the definition of overindebtedness, for example in Section 18 of the Insolvency Code (permanent lack of liquidity), because they can be a consequence of overindebtedness mostly not even are.

Only when these features are combined, as the iff does with its overindebtedness report, with anonymized personal data from debt counseling, do they make sense that can guide policy-makers in combating overindebtedness.


"To calculate the PVI, a combination of negative credit-relevant information is considered individually for the respective resident population, weighted and an overall value is calculated.

Below are the so-called soft and hard negative features (e.g. a payment default, a loan default and / or the opening of personal bankruptcy proceedings) that are used to calculate the PVI. These soft and hard negative features are divided into three levels of yellow, orange and red, depending on their characteristics. (Note: these sectors are not to be confused with the various levels of soft and hard negative features).

The soft negative features (yellow and orange levels) are
Payment disruptions at non-banks and banks.

The red level contains only hard negative features.

The features in the red level can be a clear signal of an impending or threatening situation
be an over-indebtedness situation that has already arisen.

Yellow level

• Only completed negative features
• Not a negative feature and with a current credit obligation and SCHUFA risk rate
by score> 10%
• A current negative feature only from the non-banking sector
• More than one current negative from one or more non-banking industries
The so-called non-banks are the following sectors:
Trade, mail order, internet trade, telecommunications etc.
Level orange
• Open negative feature from a bank younger than 1 year
• Open negative characteristic from a bank younger than 1 year and in the non-banking sector
• Open negatives from at least one bank younger than 1 year
• Negative characteristics history for at least one bank of 1-3 years

Open negative features are payment disruptions, i. H. open, adequately reminded
and undisputed claims that have not yet been settled through payments.

Level red

• Feature affidavit (EV) or arrest warrant for submitting an EV
• Characteristic of personal bankruptcy
• People with a search order

Search order means: A contractual partner of SCHUFA has an open, sufficiently dunned and undisputed claim against a customer who has moved unknown. "


As is known, SCHUFA also sells a scoring value from its data for all borrowers, which the banks use when granting loans and, above all, when determining the loan price in such a way that poorer consumers are disadvantaged.

Since the SCHUFA is now so loud and claims a connection between the address and the credit risk in public, we have to assume that the address is also included in the strictly confidential composition of the scoring. This would be an absolutely inadmissible individual discrimination of customers, which is not covered by the SCHUFA clause and violates data protection. In our opinion, SCHUFA is obliged to provide evidence.


We had received corresponding information from third parties about Post Adress GmbH on the use of postal addresses, which we naturally cannot check. Post Adress GmbH wrote to us about this:

"Post Adress is only a sales intermediary for the so-called" risk index "developed or offered by the service provider microm. This product describes the statistical probabilities of payment defaults on the basis of a residential environment file (on a cell basis) - this means that it is anonymized Data and not addresses or addresses. "

However, we had not assumed anything else, because the so-called anonymization is unfortunately of no use to the individual if he has his zip code attached as a personal feature that has lost his innocence. For these reasons, the use of postcodes for scoring is prohibited by law in the USA, for example.

However, the following sentence reassures us:

"Incidentally, this range of services is an absolute marginal business of Post Adress, which we also intend to discontinue due to this fact"


Against this background, the interview in Tagesspiegel can also be seen, which for the first time in Germany shows an editor who not simply announces the annual SCHUFA cards as a sensation in the manner of court journalists, but also questions them once. Bill Dedman from Atlanta became famous in the USA with his series of articles "The Color of Money", "The (skin) color of money" and caused a considerable upheaval in public thinking, which ultimately resulted in various anti-discrimination laws and the community Reinvestment Act.

Instead, magazines in Germany used the title "Atlas of the poor debtors" and made themselves a pioneer of this modern form of discrimination.