Black Box Winter
Summary
Denied power by an algorithm she never consented to, a woman teams with noyb’s Martin Baumler to turn her blackout into a precedent-setting fight over Article 22—forcing Europe’s credit engines to choose between explainability with human review or no automation at all.
Vienna, present day. Anonymous Komplandt applies for an electricity contract and is shut out in the time it takes a cursor to blink. No reason. No human. Just a black‑box score from KSV1870—data points she never agreed to, stitched into a verdict she can’t contest. She walks into noyb’s offices with a notebook full of timestamps and meter photos; Martin Baumler, a quietly relentless litigator with Article 22 engraved in muscle memory, sees a test case. With the CJEU’s SCHUFA ruling as his lodestar, he aims to pry open the algorithm that turned a clerical rumor into a life decision.
As the Austrian Data Protection Authority issues a targeted processing ban and demands intelligible explanations, a national fight erupts. Inside KSV1870, compliance and data science collide over a scoring engine whose power is its opacity; at energy provider Unsere Wasserkraft, spreadsheets and PR statements can’t answer a basic question: who actually flipped the switch? Investors, ministers, and rival agencies circle while a whistleblower drops a map of a gray market for “clean profiles,” where mislinked identities and stale debts propagate like supply‑chain bugs. noyb counters with a radical tool—the Score Bill of Materials—an SBOM-style trace of every data source, inference, and vendor hop, turning privacy law into a forensic chase. Nighttime hearings, code‑and‑compliance audits, boardroom brinkmanship, and the human cost of a “design choice” gather into a pressure cooker.
Winter creeps closer. If industry appeals succeed, the black‑box regime returns; if transparency and meaningful human review hold, Europe’s credit and utility markets must reboot overnight. In a climactic public hearing where SCHUFA’s precedent looms, Baumler has to translate doctrine into operational constraints—consent and explainability as civil‑rights infrastructure—or accept that automation gets to decide who keeps the lights on. Black Box Winter asks a stark question in the glow of a phone screen: can one woman’s denial unravel an entire data supply chain before the cold sets in?
Inspired by: Noyb WIN: Austrian authority forbids unlawful credit scoring by KSV1870 - https://noyb.eu/en/noyb-win-austrian-authority-forbids-unlawful-credit-scoring-ksv1870