# TUiR Warta S.A.: Insufficient fulfilment of data breach notification obligations

- Type: Enforcement
- Source: Polish National Personal Data Protection Office (UODO)
- Date: 2020-12-09
- Original: https://www.enforcementtracker.com/ETid-510
- Canonical: https://overview.legal/posts/46625
- Topics: Data Breaches, Notification Obligation, Article 19 GDPR - Notification of Rectification, Erasure or Restriction, Notified Body Reporting and Notification Obligations, Insurance, Controllers, Personal Data, Processing Agreement, Supervisory Authorities, Data Controller

## Summary

An insurance agent hired by the controller had sent an email to unauthorized third parties in regard to insurance policies that contained personal data of two of the company's customers after they had mistakenly provided false email addresses. The leaked data included data such as the names, email adresses and postal addresses of the data subjects. The controller had not informed either the Polish DPA nor the data subjects about the data breach in a timely manner within 72 hours. The controller

## Full text

An insurance agent hired by the controller had sent an email to unauthorized third parties in regard to insurance policies that contained personal data of two of the company's customers after they had mistakenly provided false email addresses. The leaked data included data such as the names, email adresses and postal addresses of the data subjects. The controller had not informed either the Polish DPA nor the data subjects about the data breach in a timely manner within 72 hours. The controller believed that there was no breach requiring notification because the data subjects themselves had mistakenly provided incorrect e-mail addresses. The Polish DPA states that this circumstance does not release the controller from its obligation to report this data breach in a timely manner.

GDPR Articles: Art. 33 (1) GDPR, Art. 34 (1) GDPR
Industry: Finance, Insurance and Consulting

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