# Bank: Insufficient involvement of data protection officer

- Type: Enforcement
- Source: Belgian Data Protection Authority (APD)
- Date: 2021-12-16
- Original: https://www.enforcementtracker.com/ETid-994
- Canonical: https://overview.legal/posts/47109
- Topics: Notified Body Responsibilities and Operational Obligations, Supervisory Authorities, Processing Agreement, Notified Body Independence, Insurance, Scientific Panel Independence

## Summary

The Belgian DPA has imposed a fine of EUR 75,000 on a bank. The DPA identified a conflict of interest regarding the data protection officer. In addition to his work as data protection officer, he was also head of a department to which he had to report in his capacity as data protection officer. The DPA considered this to be a violation of Art. 38 (6) GDPR.

## Full text

The Belgian DPA has imposed a fine of EUR 75,000 on a bank. The DPA identified a conflict of interest regarding the data protection officer. In addition to his work as data protection officer, he was also head of a department to which he had to report in his capacity as data protection officer. The DPA considered this to be a violation of Art. 38 (6) GDPR.

GDPR Articles: Art. 38 (6) GDPR
Industry: Finance, Insurance and Consulting

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Generated by overview.legal · https://overview.legal/posts/47109 · 2026-08-22