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Enforcement

Regulatory actions, fines, warnings, and enforcement decisions

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€900 Cerrajero Online: Insufficient fulfilment of information obligations The company had collected personal data without providing accurate information about data collection in its data protection declaration pursuant to Article 13 of the GDPR. SPAIN ·AEPD ·Art. 13 Personal Data Supervisory Authorities Transparency Nov 6, 2019
€1,770 L. Sp. z o.o.: Non-compliance with general data processing principles The Polish DPA (UODO) imposed a fine of EUR 1,770 on L. Sp. z o.o. for the video surveillance of a residential community, which was not in compliance with the provisions of the… POLAND ·UODO ·Art. 5 Personal Data Processing Video Surveillance Nov 1, 2019
Deutsche Wohnen SE: Non-compliance with general data processing principles In addition to sanctioning violations of privacy by design principles (Art. 5 GDPR, Art. 25 GDPR - see separate entry), the Berlin data protection commissioner imposed further… GERMANY ·Art. 5 ·Non-compliance with general data processing principles Privacy by Design Privacy by Design & Default Privacy by Default Oct 30, 2019
€511 Employer: Insufficient fulfilment of data subjects rights The pecuniary sanction of EUR 511 was imposed on an employer for refusal to grant access to the personal data of a data subject who submitted an application for access to his… BULGARIA ·CPDP ·Art. 12, 15 Personal Data Employees Oct 28, 2019
€70,000 LGS Handling Ltd, Louis Travel Ltd, and Louis Aviation Ltd: Insufficient legal basis for data processing The decision found that the use of the Bradford factor for profiling and monitoring sick leave constituted unlawful processing of personal data in breach of Article 6 and Article… CYPRUS ·Cyprus DPA ·Art. 6, 9 Personal Data Types of Special Categories of Personal Data Processing Oct 25, 2019
€10,000 LGS Handling Ltd, Louis Travel Ltd, and Louis Aviation Ltd: Insufficient legal basis for data processing The decision found that the use of the Bradford factor for profiling and monitoring sick leave constituted unlawful processing of personal data in breach of Article 6 and Article… CYPRUS ·Cyprus DPA ·Art. 6, 9 Personal Data Types of Special Categories of Personal Data Processing Oct 25, 2019
€2,000 LGS Handling Ltd, Louis Travel Ltd, and Louis Aviation Ltd: Insufficient legal basis for data processing The decision found that the use of the Bradford factor for profiling and monitoring sick leave constituted unlawful processing of personal data in breach of Article 6 and Article… CYPRUS ·Cyprus DPA ·Art. 6, 9 Personal Data Types of Special Categories of Personal Data Processing Oct 25, 2019
€36,000 Vodafone España, S.A.U.: Insufficient legal basis for data processing The claimant, whose data had been provided to the company by his daughter, as authorised by him, received a call from the company offering its services, which he refused. However,… SPAIN ·AEPD ·Art. 5, 6 Personal Data Consent Processing Oct 25, 2019
€20,000 Wind Hellas Telecommunications: Insufficient fulfilment of data subjects rights Among other things, the company has ignored objections raised by affected parties against advertising calls. GREECE ·HDPA ·Art. 21 Personal Data Direct Marketing Right to Object Oct 18, 2019
€9,380 Major of Aleksandrów Kujawski: Insufficient data processing agreement No data processing agreement has been concluded with the company whose servers contained the resources of the Public Information Bulletin (BIP) of the Municipal Office in… POLAND ·UODO ·Art. 28 Processors Personal Data Processing Oct 18, 2019
€2,500 UTTIS INDUSTRIES SRL: Insufficient fulfilment of information obligations The sanctions were applied to the controller because he could not prove that the data subjects were informed about the processing of personal data / images through the video… ROMANIA ·ANSPDCP ·Art. 5, 6, 12 +1 Personal Data Controllers Processing Oct 17, 2019
€60,000 Xfera Moviles S.A.: Insufficient legal basis for data processing Xfera Movile has used personal data without a legal basis for the conclusion of a telephone contract and has continued to process personal data even when the data subject… SPAIN ·AEPD ·Art. 5, 6 Personal Data Processing Telecommunications Oct 16, 2019
€47,000 ClickQuickNow: Non-compliance with general data processing principles The UODO imposed a fine of EUR 47000 for obstructing the exercise of the right of withdrawal for the processing of personal data. The company has not taken appropriate technical… POLAND ·UODO ·Art. 5 Personal Data Processing Right to be Forgotten Oct 16, 2019
€15,000 Raiffeisen Bank SA: Insufficient technical and organisational measures to ensure information security Original fine summary: Raiffeisen Bank Romania carried out scoring assessments on the basis of personal data of individuals registered on the Vreau Credit platform provided by the… ROMANIA ·ANSPDCP ·Art. 32 Security Personal Data Insurance Oct 9, 2019
€20,000 Vreau Credit SRL: Insufficient technical and organisational measures to ensure information security Raiffeisen Bank Romania carried out scoring assessments on the basis of personal data of individuals registered on the Vreau Credit platform provided by the platform's staff via… ROMANIA ·ANSPDCP ·Art. 32, 33 Personal Data Security Supervision Oct 9, 2019
€400 Legal Person: Insufficient fulfilment of data subjects rights The Czech DPA has imposed a fine of EUR 400 on a legal person. The accused did not meet the objection of two data subjects to the processing of their personal data for direct… CZECH REPUBLIC ·ÚOOÚ (CZ) ·Art. 21 Personal Data Direct Marketing Right to Object Oct 8, 2019
€5,112 The Ministry of Interior Affairs: Insufficient legal basis for data processing The fine of EUR 5,112 was imposed on the Ministry of Interior Affairs for unlawfully processing the personal data of data subject A.K. The Ministry of Interior sent the personal… BULGARIA ·CPDP ·Art. 5, 6 Personal Data Processing Public Authority Oct 8, 2019
€511 B.D.: Insufficient cooperation with supervisory authority The fine of EUR 511 was imposed on B.D. for failure to provide access to information which the Commission for Personal Data Protection needed for performance of its tasks and… BULGARIA ·CPDP ·Art. 31 Supervision Supervisory Authorities Personal Data Oct 7, 2019
€2,000 Legal Person: Insufficient legal basis for data processing The Czech DPA has imposed a fine of EUR 2,000 on a legal person. The accused circumvented the law when, instead of providing social services with proper authorization, it did so… CZECH REPUBLIC ·ÚOOÚ (CZ) ·Art. 5, 12, 30 Personal Data Processing Supervisory Authorities Oct 4, 2019
€9,000 Inteligo Media SA: Insufficient legal basis for data processing As part of the registration process on the webseite avocatnet.ro, the operator used an unfilled checkbox, by means of which users could declare that they did not wish to receive… ROMANIA ·ANSPDCP ·Art. 5, 6 Consent Personal Data Processing Sep 26, 2019
€195,407 Delivery Hero: Insufficient fulfilment of data subjects rights According to the findings of the Berlin data protection officer, Delivery Hero Germany GmbH had not deleted accounts of former customers in ten cases, even though those data… GERMANY ·Art. 15, 17, 21 ·Insufficient fulfilment of data subjects rights Personal Data Direct Marketing Supervisory Authorities Sep 19, 2019
€10,000 Merchant: Non-compliance with general data processing principles The Belgian data protection authority has imposed a fine of 10,000 euros on a merchant who wanted to use an electronic identity card (eID) to create a customer card. The DPA's… BELGIUM ·APD/GBA ·Art. 5 Personal Data Identification Processing Sep 17, 2019
€660,000 Morele.net: Insufficient technical and organisational measures to ensure information security The Polish data protection authority imposed a fine of over PLN 2.8 million (approx. €644,780) on Morele.net for insufficient organisational and technical safeguards, which led to… POLAND ·UODO ·Art. 32 Security Personal Data Integrity and Confidentiality Principle Sep 10, 2019
€5,113 Telecommunication service provide: Insufficient legal basis for data processing The pecuniary sanctions of EUR 1, 022 and EUR 5, 113 were imposed on a telecommunications service provider and its commercial representative in Bulgaria for unlawful processing of… BULGARIA ·CPDP ·Art. 6, 25 Personal Data Telecommunications Consent Sep 3, 2019
€1,121 Private enforcement agent: Insufficient fulfilment of data subjects rights The fine of EUR 1, 121 was imposed on a private enforcement agent for processing of the personal data of data subject through recording by technical means for video surveillance… BULGARIA ·CPDP ·Art. 12, 15 Personal Data Supervision Processing Sep 3, 2019
€28,100 National Revenue Agency: Insufficient legal basis for data processing The pecuniary sanction of EUR 28, 121 was imposed on the National Revenue Agency for unlawful processing of the personal data of data subject G.B.I. The personal data of G.B.I.… BULGARIA ·CPDP ·Art. 6, 58 Personal Data Supervision Public Authority Sep 3, 2019
€1,022 Telecommunication service provide: Insufficient legal basis for data processing The pecuniary sanctions of EUR 1, 022 and EUR 5, 113 were imposed on a telecommunications service provider and its commercial representative in Bulgaria for unlawful processing of… BULGARIA ·CPDP ·Art. 6, 25 Personal Data Telecommunications Consent Sep 3, 2019
Deliberação 2019/494 In its Opinion 20/2018 concerning the draft of Law 58/2019 which ensures the implementation of the GDPR in the portuguese national legal framework, the DPA drew the attention of… Deliberação 2019/494 ·Portugal ·CNPD (PT) Controllers Legitimate Interest Personal Data Sep 3, 2019
€11,760 Commercial representative of telecommunication service provider: Insufficient legal basis for data processing The pecuniary sanction of EUR 11, 760 was imposed on the commercial representative of telecommunications service provider for unlawful processing of the personal data of a data… BULGARIA ·CPDP ·Art. 6 Personal Data Telecommunications Representatives Sep 3, 2019
€511,000 DSK Bank: Insufficient technical and organisational measures to ensure information security Leakage of personal data due to inadequate technical and organisational measures to ensure the protection of information security. Third parties had access to over 23000 credit… BULGARIA ·CPDP ·Art. 32 Personal Data Security Insurance Aug 28, 2019
€2.6M National Revenue Agency: Insufficient technical and organisational measures to ensure information security Leakage of personal data in a hacking attack due to inadequate technical and organisational measures to ensure the protection of information security. It was found that personal… BULGARIA ·CPDP ·Art. 32 Security Personal Data Public Authority Aug 28, 2019
€7,000 Online Services: Insufficient fulfilment of data subjects rights A merchant who provides services in an online store has infringed the 'right to be forgotten' pursuant to Art. 17 GDPR when he was repeatedly requested by a data subject to delete… LATVIA ·DSI ·Art. 17 Personal Data Right to be Forgotten Direct Marketing Aug 26, 2019
€18,630 School in Skellefteå: Insufficient legal basis for data processing A school in Skellefteå made a trial to use facial recognition technology. The fine was imposed against the school which had used facial recognition technology to monitor the… SWEDEN ·Art. 5, 9, 35 +1 ·Insufficient legal basis for data processing Types of Special Categories of Personal Data Personal Data Monitoring Aug 20, 2019
€60,000 AVON COSMETICS: Insufficient legal basis for data processing A consumer claimed that AVON COSMETICS had unlawfully processed his data without adequately verifying his identity, which led to his data being erroneously entered in a register… SPAIN ·AEPD ·Art. 6 Personal Data Processing Supervisory Authorities Aug 16, 2019
€1,715 Government Office Managing the Real Estate Register: Non-compliance with general data processing principles The owners of a real estate complained that the government office posted its decision on the change in the person of the lessee (which concluded a lease agreement with real estate… HUNGARY ·NAIH ·Art. 5, 14 Personal Data Processing Public Authority Aug 8, 2019
€150,000 PWC Business Solutions: Insufficient legal basis for data processing The processing of employee personal data was based on consent. The HDPA found that consent as legal basis was inappropriate, as the processing of personal data was intended to… GREECE ·HDPA ·Art. 5, 6, 13 +1 Legitimate Interest Personal Data Controllers Jul 30, 2019
€3,000 LEGAL COMPANY & TAX HUB SRL: Insufficient technical and organisational measures to ensure information security The fine was imposed because adequate technical and organizational measures to ensure a level of security appropriate to the risk of processing were not implemented. This has led… ROMANIA ·ANSPDCP ·Art. 32 Security Personal Data Integrity and Confidentiality Principle Jul 5, 2019
€15,000 WORLD TRADE CENTER BUCHAREST SA: Insufficient technical and organisational measures to ensure information security The breach of data security was that a printed paper list used to check breakfast customers and containing personal data of 46 clients who stayed at the hotel's WORLD TRADE CENTER… ROMANIA ·ANSPDCP ·Art. 32 Security Personal Data Healthcare Jul 2, 2019
€130,000 UNICREDIT BANK SA: Insufficient technical and organisational measures to ensure information security The fine was issued as a result of the failure to implement appropriate technical and organisational measures (related to (1) the determination of the processing means/operations,… ROMANIA ·ANSPDCP ·Art. 5, 25 Security Personal Data Processing Jun 27, 2019
€2,850 HUNGARY DPA: Insufficient legal basis for data processing The individual requested the deletion of his contact data (including his telephone number), however the controller further processed his contact data for claim enforcement… NAIH ·Art. 5, 6, 17 ·Insufficient legal basis for data processing Legitimate Interest Personal Data Controllers Jun 26, 2019
€15,150 HUNGARY DPA: Insufficient fulfilment of data breach notification obligations The data controller did not fulfil its data breach notification obligations when a flash memory with personal data was lost. NAIH ·Art. 33 ·Insufficient fulfilment of data breach notification obligations Notification Obligation Data Breaches Notified Body Reporting and Notification Obligations Jun 25, 2019
€400 Legal Person: Insufficient fulfilment of data subjects rights The Czech DPA has imposed a fine of EUR 400 on a legal person. The accused did not comply with the data subject's request to delete the personal data from its website, even after… CZECH REPUBLIC ·ÚOOÚ (CZ) ·Art. 17 Personal Data Processing Agreement Supervisory Authorities Jun 12, 2019
€2,850 Claim management company: Insufficient legal basis for data processing The complainants stated during the case that they concluded a credit agreement with the bank, which sold its claim against the complainants and transferred their respective data… HUNGARY ·NAIH ·Art. 5, 6 Legitimate Interest Controllers Personal Data Jun 3, 2019
€2,000 Local bank: Insufficient fulfilment of data subjects rights Customer of a local bank requested access to telephone conversation recordings as well as to CCTV recordings. The bank provided the copies of the recordings of telephone… HUNGARY ·NAIH ·Art. 12, 15, 18 Personal Data Controllers Insurance May 31, 2019
€2,000 Mayor: Insufficient legal basis for data processing The administrative fine was imposed for the misuse of personal data by a mayor for campaign purposes. BELGIUM ·APD/GBA ·Art. 5, 6 Personal Data Processing Public Authority May 28, 2019
€92,146 Organizer of SZIGET festival and VOLT festival: Insufficient legal basis for data processing The NAIH found that there were inappropriate legal bases is use and that the controller did not comply with the principle of purpose limitation. Also, information on the data… HUNGARY ·NAIH ·Art. 5, 6, 13 Personal Data Controllers Processing May 23, 2019
€286 Directorate of Social and Child Welfare Institutions of the Ferencvaros District of Budapest: Insufficient fulfilment of data breach notification obligations The employee of the Directorate sent by mistake 9 letters to the wrong recipient, which contained personal data of 18 data subjects (including data of children, criminal data and… HUNGARY ·NAIH ·Art. 33 Notification Obligation Data Breaches Notified Body Reporting and Notification Obligations May 21, 2019
€1,400 Police Officer: Insufficient legal basis for data processing The police officer, using his official user ID but without reference to official duties, queried the owner data concerning the license plate of a person who he did not know well… GERMANY ·Art. 6 ·Insufficient legal basis for data processing Personal Data Consent Public Authority May 9, 2019
€194 CZECH REPUBLIC DPA: Insufficient fulfilment of data subjects rights Information was not provided. ÚOOÚ (CZ) ·Art. 15 ·Insufficient fulfilment of data subjects rights Personal Data Supervisory Authorities Processing Agreement May 6, 2019
€120,000 Oslo Municipal Education Department: Insufficient technical and organisational measures to ensure information security Fine for security vulnerabilities in a mobile messaging app developed for use in an Oslo school. The app allows parents and students to send messages to school staff. Due to… NORWAY ·Datatilsynet (NO) ·Art. 32 Security Personal Data Right of Access Apr 29, 2019