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Enforcement

Regulatory actions, fines, warnings, and enforcement decisions

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CNPD (Portugal) - 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 ·Art. 2, 3, 5 +8 Controllers Processing Personal Data Sep 3, 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 ·KZLD ·Art. 6, 25 Personal Data Telecommunications Integrity and Confidentiality Principle 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 ·KZLD ·Art. 6, 58 Personal Data Integrity and Confidentiality Principle 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 ·KZLD ·Art. 6, 25 Telecommunications Personal Data Integrity and Confidentiality Principle Sep 3, 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 Biometric Data Biometric 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 Law Enforcement 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 Education IP Address Aug 8, 2019
€200 Private person (YouTube-Channel): Insufficient legal basis for data processing The private person used a dashcam to make recordings of public road traffic and then published them on YouTube as a compilation. GERMANY ·Art. 5, 6 ·Insufficient legal basis for data processing Processing Supervisory Authorities Aug 5, 2019
€4,290 Public area maintenance company: Non-compliance with general data processing principles An ex-employee complained that his employer unlawfully monitored his work by its CCTV. The employer argued that CCTV monitoring was necessary to assess, whether the employee… HUNGARY ·NAIH ·Art. 5, 6, 13 Monitoring Video Surveillance Audit Logs Aug 2, 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 Fairness & Transparency Controllers Jul 30, 2019
€8,575 Budapest Environs Regional Court: Insufficient legal basis for data processing The chairman of the Budapest Environs Regional Court organised a meeting for court officials, during which he stated that he quit from the Hungarian Association of Judges and… HUNGARY ·NAIH ·Art. 5, 6 Education IP Address Processing Jul 17, 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 Data Breaches Integrity and Confidentiality Principle Security 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 Healthcare Personal Data Jul 2, 2019
€11,000 Private person (soccer coach): Insufficient legal basis for data processing The fine was imposed on a soccer coach who had secretly filmed female players while they were naked in the shower cubicle for years. AUSTRIA ·dsb ·Art. 6 Processing Supervisory Authorities Jul 1, 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 Insurance Personal Data Jun 27, 2019
€2,850 Financial Enterprise: Insufficient legal basis for data processing A client of a financial enterprise complained that the financial enterprise transferred his data after he objected against the processing and did not provide information on the… HUNGARY ·NAIH ·Art. 5, 6, 21 Legitimate Interest Controllers Insurance Jun 26, 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 Controllers Personal Data 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 Data Breaches Notification Obligation Notified Body Reporting and Notification Obligations Jun 25, 2019
€20,000 Employer UNIONTRAD COMPANY: Insufficient legal basis for data processing Between 2013 and 2017, the CNIL received complaints from several employees of the company who were filmed at their workstation. On two occasions, it alerted the company to the… FRANCE ·CNIL ·Art. 5, 12, 13 +1 Video Surveillance Employees Processing Jun 13, 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 Insurance Jun 3, 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 ·Art. 5, 6 Personal Data Education 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 Controllers IP Address Personal Data May 23, 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 Public Authority Consent May 9, 2019
€12,950 Sports association: Insufficient legal basis for data processing One sports association published personal data referring to judges who were granted judicial licenses online. However, not only their names were provided, but also their exact… POLAND ·UODO ·Art. 6 Personal Data Liability Controllers Apr 25, 2019
€50,000 Italian political party Movimento 5 Stelle: Insufficient technical and organisational measures to ensure information security A number of websites affiliated to the Italian political party Movimento 5 Stelle are run, by means of a data processor, through the platform named Rousseau. The platform had… ITALY ·Garante ·Art. 32 Controllers Data Breaches Processors Apr 17, 2019
€9,400 HUNGARY DPA: Insufficient legal basis for data processing A data controller used a, in the point of view of NAIH, wrong legal basis for processing of personal data (Art. 6.1.b) for the assignment of claims. NAIH ·Art. 5, 6 ·Insufficient legal basis for data processing Controllers Processing Personal Data Apr 17, 2019
€510 Medical centers: Insufficient legal basis for data processing The sanction of 510 EUR was imposed on each medical center for unlawful processing of the personal data of data subject G.B. by a medical centre for the purpose of changing his… BULGARIA ·KZLD ·Art. 5, 6, 9 Healthcare Integrity and Confidentiality Principle Healthcare Apr 8, 2019
€1,900 HUNGARY DPA: Insufficient fulfilment of data subjects rights The data controller did not fulfil the data subject's access request. NAIH ·Art. 15 ·Insufficient fulfilment of data subjects rights Right of Access Procedures Personal Data Controllers Apr 5, 2019
€5,100 A.P. EOOD: Insufficient legal basis for data processing The sanction was imposed on personal data administrator A.P. EOOD for unlawful processing of personal data. The personal data of data subject D.D. was used by A.P. EOOD for… BULGARIA ·KZLD ·Art. 5, 6 Personal Data Integrity and Confidentiality Principle Processing Mar 26, 2019
€220,000 Private company working with data from publicly available sources: Insufficient fulfilment of information obligations The fine concerned the proceedings related to the activity of a company which processed the data subjects’ data obtained from publicly available sources, inter alia from the… POLAND ·UODO ·Art. 14 Controllers Personal Data Processing Mar 26, 2019
€10,000 CZECH REPUBLIC DPA: Non-compliance with general data processing principles Data was not only processed if adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed ('data minimisation') and not only kept… UOOU ·Art. 5 ·Non-compliance with general data processing principles Retention Period Storage Limitation Personal Data Mar 21, 2019
€50,000 N26: Insufficient legal basis for data processing The fine was imposed against against a bank (according to a newspaper N26) that had processed 'personal data of all former customers' without permission.The Bank has acknowledged… GERMANY ·Art. 6 ·Insufficient legal basis for data processing Insurance Personal Data Processing Mar 1, 2019
€582 CZECH REPUBLIC DPA: Insufficient technical and organisational measures to ensure information security Data was not processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental… UOOU ·Art. 32 ·Insufficient technical and organisational measures to ensure information security Integrity and Confidentiality Principle Security Professional Secrecy Feb 28, 2019
€3,200 Mayor's Office of the city of Kecdkemét: Insufficient legal basis for data processing The fine was imposed on the Mayor’s Office of the city of Kecskemét for unlawful disclosure of the personal information of a whistleblower.NAIH imposed the fine after an employee… HUNGARY ·NAIH ·Art. 5, 6 Data Breaches Public Authority Education Feb 28, 2019
€27,100 Telecommunication service provider: Insufficient legal basis for data processing Repeated registration of prepaid services without the knowledge and consent of the data subject Employees of the telecommunications provider have used personal data and registered… BULGARIA ·KZLD ·Art. 5, 6 Telecommunications Personal Data Consent Feb 26, 2019
€1,560 Debt collector: Non-compliance with general data processing principles A data subject requested information about and erasure of the data processed, which the debt collector refused stating that it could not identify the subject. For identification… HUNGARY ·NAIH ·Art. 5 Fairness & Transparency Personal Data Controllers Feb 20, 2019
€1,560 Bank: Non-compliance with general data processing principles A bank mistakenly sent SMS messages about a subject's credit card debt to the telephone number of another person. After receiving an incorrect telephone number from the client at… HUNGARY ·NAIH ·Art. 5 Personal Data Insurance IP Address Feb 8, 2019
€2,500 Private person: Insufficient legal basis for data processing The fine was impossed against a private person who sent several e-mails between July and September 2018, in which he used personal e-mail addresses visible to all recipients, from… GERMANY ·Art. 5, 6 ·Insufficient legal basis for data processing Recipient Criminal Data IP Address Feb 5, 2019
€1,165 Credit brokerage: Insufficient technical and organisational measures to ensure information security Data was not processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental… CZECH REPUBLIC ·UOOU ·Art. 32 Integrity and Confidentiality Principle Security Professional Secrecy Feb 4, 2019
€50M Google LLC: Insufficient legal basis for data processing The fine was imposed on the basis of complaints from the Austrian organisation 'None Of Your Business' and the French NGO 'La Quadrature du Net'. The complaints were filed on 25th… FRANCE ·CNIL ·Art. 5, 6, 13 +1 Fairness & Transparency Transparency Telecommunications Jan 21, 2019
€500 Bank: Insufficient legal basis for data processing A bank gained personal data concernign a student wihtout a legal basis. BULGARIA ·KZLD ·Art. 5, 6 Insurance Personal Data Processing Jan 17, 2019
€388 Employer: Insufficient legal basis for data processing A former employee of a company requested the deletion of information relating to him/her which was published on the Facebook website of the employer and which was still available… CZECH REPUBLIC ·UOOU ·Art. 6 Social Media IP Address Processing Jan 10, 2019
€20,000 Employer: Non-compliance with general data processing principles Video surveillance cameras have not only been used to protect property, but have also monitored employees (violation of principle of data minimisation). SPAIN ·aepd ·Art. 5 Video Surveillance Monitoring Retention Period Jan 1, 2019
€48,000 TELEFONICA MOVILES ESPAÑA, S.A.U.: Non-compliance with general data processing principles The claimant's bank account was charged by the company with two invoices for the services he had contracted, however, displaying personal data of another customer. The initial… SPAIN ·aepd ·Art. 5 Personal Data IP Address Telecommunications Jan 1, 2019
€160,000 Taxa 4x35: Non-compliance with general data processing principles The Danish DPA reported the taxi company to the police and recommended a fine (of 1.2M DKK) for non-adherence to the data-minimization principle. While the company deleted the… DENMARK ·Datatilsynet ·Art. 5 Administrative Fines on Union Institutions, Bodies, Offices and Agencies Fines IP Address Jan 1, 2019
€14,000 Doctor: Insufficient legal basis for data processing A patient complained to the Commissioner that the request for access to her medical file was not satisfied by the hospital because the dossier could not be identified/located by… CYPRUS ·Art. 5, 6 ·Insufficient legal basis for data processing Healthcare Healthcare Controllers Jan 1, 2019
€50,000 Unknown Company: Insufficient fulfilment of data subjects rights The data controller had engaged an external company to carry out the duties of access to data according to Art. 15 GDPR. However, the engaged company conducted the correspondence… GERMANY ·Art. 15, 28 ·Insufficient fulfilment of data subjects rights Controllers Fairness & Transparency IP Address Jan 1, 2019
€2,000 Restaurant: Non-compliance with general data processing principles Video surveillance cameras have been used in violation of principle of data minimisation (monitoring also of customer areas in restaurants). GERMANY ·Art. 5 ·Non-compliance with general data processing principles Video Surveillance Monitoring Retention Period Jan 1, 2019
€3,600 AMADOR RECREATIVOS, S.L: Non-compliance with general data processing principles Surveillance of the public space by video surveillance cameras against violation of the principles of data minimisation. SPAIN ·aepd ·Art. 5 Video Surveillance Retention Period Monitoring Jan 1, 2019
GERMANY DPA: Insufficient legal basis for data processing Nine fines between EUR 350 and EUR 1,000 for unlawful use of a dashcam. Art. 6 ·Insufficient legal basis for data processing Fines Processing Agreement Processing Jan 1, 2019