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Enforcement · Data Protection Authority of Bremen 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 legal basis for data processing

The DPA of Bremen has imposed a five-digit fine on a company.

Company
GERMANY
Art. 6 GDPR

Full text

The DPA of Bremen has imposed a five-digit fine on a company. The company had sent an unredacted social plan to all affected employees in the context of dismissals due to operational reasons, resulting in the disclosure of personal data contained therein, such as date of birth, age, marital status, number of dependent children, function in the company, severe disability, etc., to all employees. The DPA found that such extensive disclosure of personal data was unlawful due to the lack of a legal basis. The DPA considered the fact that special categories of personal data, such as information on a severe disability, had also been disclosed to be an aggravating factor.

Industry: Employment

How it connects

Guidelines 1/2020 processing personal data in the context of connected vehicles and mobility related applications Guidelines on processing of personal data through video devices Guidelines ·EDPB Jan 28, 2020 Personal Data Privacy by Design & Default Processing
CJEU Bavarian Lager: Disclosing personal data in access-to-documents requests is Processing: Communication of personal data in response to a request for access to documents constitutes processing. (¶69) Jun 29, 2010 Personal Data Legitimate Interest Right to Restriction
C-252/21 Meta Platforms v noyb C-252/21 (Meta Platforms (noyb)) CJEU Jan 12, 2023 Supervisory Authorities IP Address Supervision