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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.

GSMA Limited: Insufficient legal basis for data processing

€600,000 Fine
GSMA Limited
SPAIN
Art. 6 GDPR Art. 9 GDPR Art. 14 GDPR

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The Spanish DPA has imposed a fine of EUR 600,000 on GSMA Limited. In 2022, GSMA Limited required employees of its suppliers to register on an online platform and upload proof of vaccination against COVID-19. One of the data subjects filed a complaint with the DPA as they considered the data processing to be unlawful. GSMA referred to a legal obligation and public interest, but could not provide a specific legal basis. The DPA found that less invasive safeguards would have been possible and that the affected workers were not sufficiently informed about the data processing.

Industry: Individuals and Private Associations

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