# ING Bank Śląski: Insufficient legal basis for data processing

- Type: Enforcement
- Source: Polish National Personal Data Protection Office (UODO)
- Date: 2025-08-26
- Original: https://www.enforcementtracker.com/ETid-2840
- Canonical: https://overview.legal/posts/48955
- Topics: Controllers, Processing Agreement, Insurance, Personal Data, Processing, Data Controller, Supervisory Authorities, Law Enforcement

## Summary

The Polish DPA has imposed a fine of EUR 4,323,250 on ING Bank Śląski. The controller scanned the identity documents of every customer and potential customer without a sufficient legal basis. The controller started to implement this procedure after an anti-money laundering law was introduced, but failed to assess the necessity of the data processing in each case.

## Full text

The Polish DPA has imposed a fine of EUR 4,323,250 on ING Bank Śląski. The controller scanned the identity documents of every customer and potential customer without a sufficient legal basis. The controller started to implement this procedure after an anti-money laundering law was introduced, but failed to assess the necessity of the data processing in each case.

GDPR Articles: Art. 5 (1) a), b), c) GDPR, Art. 6 (1) GDPR
Industry: Finance, Insurance and Consulting

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Generated by overview.legal · https://overview.legal/posts/48955 · 2026-08-22