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

- Type: Enforcement
- Source: Spanish Data Protection Authority (aepd)
- Date: 2023-07-28
- Original: https://www.enforcementtracker.com/ETid-2201
- Canonical: https://overview.legal/posts/48316
- Topics: Security, Personal Data, Processing Agreement, Controllers, Privacy by Design & Default, Insurance, Law Enforcement, Supervisory Authorities, Data Controller

## Summary

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 organizat

## Full text

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.

GDPR Articles: Art. 25 GDPR, Art. 32 GDPR
Industry: Finance, Insurance and Consulting

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Generated by overview.legal · https://overview.legal/posts/48316 · 2026-08-22