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Enforcement

Regulatory actions, fines, warnings, and enforcement decisions

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€60,000 Xfera Moviles S.A.: Insufficient technical and organisational measures to ensure information security An individual complainant had received an SMS from Xfera Móviles which was to be addressed to a third party and which allowed him to access the account and personal data of this… SPAIN ·aepd ·Art. 32 Telecommunications Security Personal Data Nov 19, 2019
€60,000 Corporación radiotelevisión espanola: Insufficient technical and organisational measures to ensure information security CORPORACIÓN RADIOTELEVISIÓN ESPAÑOLA and the trade union have reported a security breach to the AEPD after six unencrypted USB sticks containing personal data were lost. The… SPAIN ·aepd ·Art. 32 Encryption Healthcare Criminal Data Nov 19, 2019
€30,000 Telefónica SA: Non-compliance with general data processing principles Telefónica had charged the complainant various fees in connection with the operation of a telephone line which the complainant had never owned. The reason for this was that the… SPAIN ·aepd ·Art. 5 Accuracy IP Address Accountability Nov 14, 2019
€3,000 General Confederation of Labour ('CGT'): Insufficient legal basis for data processing The CGT, with the aim of convening a meeting, e-mailed personal data of the complainant, including her home address, family relationship, pregnancy status and the date of an… SPAIN ·aepd ·Art. 6 Personal Data IP Address Consent Nov 13, 2019
€900 TODOTECNICOS24H S.L.: Insufficient fulfilment of information obligations TODOTECNICOS24H 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 Transparency Supervisory Authorities Nov 7, 2019
€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 Transparency Supervisory Authorities Nov 6, 2019
€60,000 Vodafone España, S.A.U.: Insufficient legal basis for data processing Vodafone has sent the customer's invoice data to unauthorised third parties following a customer invoice complaint. Originally, a fine of EUR 75,000 was threatened, but was… SPAIN ·aepd ·Art. 6 Telecommunications Processing Human Resources 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 Video Surveillance Monitoring IP Address Nov 1, 2019
€150,000 LATVIA DPA: Insufficient legal basis for data processing Unlawful data processing. No further information available yet. DSI ·Art. 6 ·Insufficient legal basis for data processing Processing Processing Agreement Supervisory Authorities Nov 1, 2019
€5,000 Restaurant: Non-compliance with general data processing principles Excessive use of video surveillance in violation of the principle of data minimization. GERMANY ·Art. 5 ·Non-compliance with general data processing principles Video Surveillance Monitoring IP Address Nov 1, 2019
€50,000 Menzis (Health Insurance Company): Non-compliance with general data processing principles Marketing staff had access to patient data. Among other things, this violated the purpose limitation principle. THE NETHERLANDS ·AP ·Art. 5 Insurance Healthcare Health Data Oct 31, 2019
€6,000 Jocker Premium Invex: Insufficient legal basis for data processing After registering for a local census, Jocker Premium Invex had sent the applicant postal advertisements and commercial offers, although data such as first name, surname and postal… SPAIN ·aepd ·Art. 6 Processing Public Authority Public Sector Oct 31, 2019
€900,000 UWV (Dutch employee insurance service provider): Insufficient technical and organisational measures to ensure information security As the UWV (the Dutch employee insurance service provider - 'Uitvoeringsinstituut Werknemersverzekeringen') did not use multi-factor authentication when accessing the online… THE NETHERLANDS ·AP ·Art. 32 Access Controls Security Health Data Oct 31, 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 Default Fines Privacy by Design Oct 30, 2019
€16M Austrian Post: Insufficient legal basis for data processing The Austrian DPA has imposed a fine of EUR 16,000,000 on the Austrian Post. The controller had sold information regarding the political affinity to third parties without a… AUSTRIA ·dsb ·Art. 5, 6 Controllers Processing Agreement Processing Oct 29, 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 ·KZLD ·Art. 12, 15 Personal Data Employees Oct 28, 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 ·Art. 6, 9 ·Insufficient legal basis for data processing Integrity and Confidentiality Principle Audit Logs Fines Oct 25, 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 ·Art. 6, 9 ·Insufficient legal basis for data processing Integrity and Confidentiality Principle Fines Audit Logs 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 ·Art. 6, 9 ·Insufficient legal basis for data processing Integrity and Confidentiality Principle Audit Logs Fines 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 Consent Personal Data Telecommunications Oct 25, 2019
€100,000 Food company: Insufficient technical and organisational measures to ensure information security The company had set up an applicant portal on its website where interested parties could submit their application documents online. However, the company did not offer an encrypted… GERMANY ·Art. 5, 32 ·Insufficient technical and organisational measures to ensure information security Encryption Security Inspection Access Rights and Cooperation Obligations Oct 24, 2019
€7,400 Military Hospital: Insufficient fulfilment of data breach notification obligations A military hospital did not meet the reporting deadline for data breaches. Another part of the fine relates to a lack of technical and organisational measures. HUNGARY ·NAIH ·Art. 32, 33 Notification Obligation Data Breaches Notified Body Reporting and Notification Obligations Oct 24, 2019
€60,000 Vodafone España, S.A.U.: Non-compliance with general data processing principles Vodafone sent an invoice history to the subscriber as part of the invoice complaint by the subscriber. The history also contained invoice data of an unknown third party. SPAIN ·aepd ·Art. 5 Telecommunications IP Address Processing Oct 23, 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 Right to Object Telecommunications Direct Marketing 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 Processing Agreement IP Address Public Authority 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 Video Surveillance Personal Data Monitoring 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 Telecommunications Processing 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 Right to be Forgotten Personal Data Consent Oct 16, 2019
€8,000 Iberdrola Clientes: Insufficient cooperation with supervisory authority Iberdrola Clientes, an electricity company, had refused to make a request to a person to change its electricity supplier because it claimed that its data would be included in the… SPAIN ·aepd ·Art. 31 Supervision Supervisory Authorities Oct 16, 2019
€2,860 Unknown Company: Non-compliance with general data processing principles An employee was on sick leave when his employer checked his desktop, laptop and emails to ensure that his work-related duties were being covered in his absence. The employer then… HUNGARY ·NAIH ·Art. 5, 6, 13 +2 Monitoring Human Resources Legitimate Interest Oct 15, 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 Insurance Personal Data 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 Security Insurance Personal Data 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 ·UOOU ·Art. 21 Right to Object Personal Data Marketing 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 ·KZLD ·Art. 5, 6 Personal Data Public Authority Processing Oct 8, 2019
€200,000 Telecommunication Service Provider: Non-compliance with general data processing principles Inappropriate technical measures resulted in the data of 8,000 customers not being deleted upon request. GREECE ·HDPA ·Art. 21, 25 Telecommunications IP Address Processing Agreement Oct 7, 2019
€200,000 Telecommunication Service Provider: Non-compliance with general data processing principles A large number of customers were subject to telemarketing calls, although they had declared an opt-out for this. This was ignored due to technical errors. GREECE ·HDPA ·Art. 5, 25 Telecommunications Direct Marketing IP Address Oct 7, 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 ·KZLD ·Art. 31 Supervisory Authorities Supervision 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 ·UOOU ·Art. 5, 12, 30 Healthcare Personal Data Processing Oct 4, 2019
€30,000 Vueling Airlines: Insufficient legal basis for data processing The Spanish Data Protection Agency (AEPD) has sanctioned Vueling Airlines with 30,000 euros for not giving users the ability to refuse their cookies and force them to use them if… SPAIN ·aepd ·Art. 5, 6 Cookies Processing Supervisory Authorities Oct 1, 2019
€15,100 Town of Kerepes: Insufficient legal basis for data processing The city based its video surveillance practice on its legitimate interests (Art. 6 (1) f GDPR). However, accordingt to Art. 6 (1) subparagraph 2 this legal basis shall not apply… HUNGARY ·NAIH ·Art. 6 Video Surveillance Legitimate Interest Public Authority Oct 1, 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 Right to Object Telecommunications 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 Healthcare 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 ·Art. 5 IP Address Personal Data Right of Access 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 Law Enforcement Personal Data 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 ·KZLD ·Art. 6, 25 Personal Data Telecommunications Integrity and Confidentiality Principle 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 ·KZLD ·Art. 6 Personal Data Integrity and Confidentiality Principle Telecommunications 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
€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 Integrity and Confidentiality Principle Personal Data Public Authority 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 ·KZLD ·Art. 12, 15 Video Surveillance Personal Data Monitoring Sep 3, 2019