# Company: Insufficient legal basis for data processing

- Type: Enforcement
- Source: Czech DPA (UOOU)
- Date: 2022-01-01
- Original: https://www.enforcementtracker.com/ETid-1760
- Canonical: https://overview.legal/posts/47875
- Topics: Controllers, Processors, Processing Agreement, Personal Data, Representatives, Processing, International Transfer, Data Controller, Data Processor, Supervisory Authorities

## Summary

The Czech DPA imposed a fine of EUR 3,400 on a company. The data subject had concluded an energy supply contract with the controller in the past, but then duly terminated it. Nevertheless, the controller assigned the previously terminated contract to a processor (sales representative) in order to contact the data subject to conclude a new contract. The DPA found that the controller had unlawfully transferred the data subject's data to the sales agent, as in the absence of an existing contract it

## Full text

The Czech DPA imposed a fine of EUR 3,400 on a company. The data subject had concluded an energy supply contract with the controller in the past, but then duly terminated it. Nevertheless, the controller assigned the previously terminated contract to a processor (sales representative) in order to contact the data subject to conclude a new contract. The DPA found that the controller had unlawfully transferred the data subject's data to the sales agent, as in the absence of an existing contract it had no valid legal basis for such transfer.

GDPR Articles: Unknown
Industry: Transportation and Energy

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Generated by overview.legal · https://overview.legal/posts/47875 · 2026-08-22