Enforcement · Data Protection Authority of Hamburg 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.

Company: Insufficient data processing agreement

€13,000 Fine
Company
GERMANY
Art. 26 GDPR
Processing Agreement IP Address Data Processor Supervisory Authorities Processing Law Enforcement Personal Data
Jan 1, 2020 Source

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Full text

The DPA from Hamburg as imposed a fine of EUR 13,000 on a company. An individual had booked and attended a course with a company, but had not paid the course fees incurred. Some time later, he registered for a course at another company of the same parent company and was rejected there. As a reason, he was told that he still had arrears with the company whose courses he had already attended. Following a complaint filed by the individual against the company, the DPA launched an investigation. It found that those companies shared a common database. It pointed out that the maintenance of a common customer database by several, legally independent companies, leads to joint responsibility according to Art. 26 GDPR. According to Art. 26 (2) GDPR, this requires an agreement that reflects the respective actual functions and relationships of the jointly responsible parties towards data subjects. However, such an agreement did not exist.

Industry: Industry and Commerce

Original document at the source datenschutz-hamburg.de

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