Enforcement · Hellenic Data Protection Authority (HDPA) EN LLM context A cited markdown file you can paste into your AI assistant (ChatGPT, Claude, a RAG or project knowledge base) to ground it in this document. Contains: this document’s text, its sections with their topics, and the full text of every law provision it applies. Everything links back to its source on overview.legal — legal information, not advice.

PWC Business Solutions: Insufficient legal basis for data processing

€150,000 Fine
PWC Business Solutions
GREECE
Art. 5 GDPR Art. 6 GDPR Art. 13 GDPR Art. 14 GDPR
Legitimate Interest Fairness & Transparency Personal Data Controllers Accountability Processing Employees IP Address
Jul 30, 2019 Source

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Guidance Guidelines 2/2018 on derogations of Article 49 under Regulation 2016/679 EDPB Case Law Maximillian Schrems v Data Protection Commissioner CJEU Guidance Art. 29 WP Guidelines on GDPR transparency requirements (WP260 rev.01) EDPB News Danish SA Declares Use of Google Analytics Unlawful Without Supplementary Measures Datatilsynet Literature GDPR Implementation Series ∙ Hungary: Introduction to the GDPR Application and a Brief History of Data Protection European Data Protection Law Review Literature GDPR Implementation Series ∙ Spain: Preparations for a New Law on Data Protection to Implement the GDPR European Data Protection Law Review

Full text

The processing of employee personal data was based on consent. The HDPA found that consent as legal basis was inappropriate, as the processing of personal data was intended to carry out acts directly linked to the performance of employment contracts, compliance with a legal obligation to which the controller is subject and the smooth and effective operation of the company, as its legitimate interest. In addition, the company gave employees the false impression that it was processing their personal data under the legal basis of consent, while in reality it was processing their data under a different legal basis. This was in violation of the principle of transparency and thus in breach of the obligation to provide information under Articles 13(1)(c) and 14(1)(c) of the GDPR. Lastly, in violation of the accountability principle, the company failed to provide the HDPA with evidence that it had carried out a prior assessment of the appropriate legal bases for processing employee personal data

Industry: Employment

Original document at the source www.dpa.gr

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