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Enforcement · Spanish Data Protection Authority (aepd) 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.

Open Bank, S.A.: Insufficient technical and organisational measures to ensure information security

€2,500,000 Fine
Open Bank, S.A.
SPAIN
Art. 25 GDPR Art. 32 GDPR

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The Spanish DPA has fined Open Bank, S.A. EUR 2,5 million. A data subject had filed a complaint with the DPA after being asked to provide proof of origin for payments on their account to ensure compliance with anti-money laundering regulations. However, the controller did not provide a secure mechanism for submitting this information, but requested the data subject to submit the documents by email. The DPA therefore found that the controller had failed to take appropriate technical and organizational measures to protect personal data, which would have been necessary given the sensitivity of the data concerned.

Industry: Finance, Insurance and Consulting

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