Enforcement · Polish National Personal Data Protection Office (UODO) 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.

PIONIER (law firm): Insufficient legal basis for data processing

€9,600 Fine
PIONIER (law firm)
POLAND
Art. 5 GDPR Art. 6 GDPR Art. 9 GDPR
Health Data Insurance Social Media Healthcare Personal Data Consent Processing Agreement Healthcare
Nov 30, 2022 Source

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The Polish DPA has imposed a fine of EUR 9,600 on the law firm PIONIER. The law firm mainly represents victims of traffic accidents in proceedings against insurance companies and other entities. In this context, it supports its clients in claims for damages as well as claims for reimbursement of medical treatment costs. During its investigation, the DPA found that the law firm processed personal data, including health data, of potential clients without a valid legal basis. The law firm obtained personal data of potential clients based on press releases as well as social media reports. This allowed it to contact potential clients and offer them its services. During an initial conversation, they asked them for their verbal consent to process their personal data up until the conclusion of a contract. However, the DPA found that the consent should have been given in a way that it could still be proven at a later stage (e.g., through a register of consents).

Industry: Finance, Insurance and Consulting

Original document at the source uodo.gov.pl

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