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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
€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 ·KZLD ·Art. 32 Personal Data Insurance Security 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 ·KZLD ·Art. 32 Security Personal Data Education 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 Right to be Forgotten Personal Data 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 Biometric Data Biometric Data Types of Special Categories of Personal Data 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
€25,000 Company in the medical sector: Insufficient fulfilment of information obligations The (none-final) fine was imposed on a company in the medical sector for non-compliance with information obligations and for not appointing a data protection officer. Update: The… AUSTRIA ·dsb ·Art. 13, 35, 37 Healthcare Healthcare Supervisory Authorities Aug 1, 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 Personal Data Jul 30, 2019
€180,000 ACTIVE ASSURANCES (car insurer): Insufficient technical and organisational measures to ensure information security Large amount of customer accounts, clients' documents (including copies of driver's licences, vehicle registration, bank statements and documents to determine whether a person had… FRANCE ·CNIL ·Art. 32 Insurance Data Breaches Integrity and Confidentiality Principle Jul 25, 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 Public Authority 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 Integrity and Confidentiality Principle Data Breaches 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 Notification Obligation Data Breaches Notified Body Reporting and Notification Obligations Jun 25, 2019
€350,000 Haga Hospital: Insufficient technical and organisational measures to ensure information security Original Fine Summary: The Haga Hospital does not have a proper internal security of patient records in place. This is the conclusion of an investigation by the Dutch Data… THE NETHERLANDS ·AP ·Art. 32 Healthcare Health Data Healthcare Jun 18, 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
€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 ·UOOU ·Art. 17 Personal Data Supervisory Authorities Processing Agreement Jun 12, 2019
€250,000 Professional Football League (LaLiga): Insufficient fulfilment of information obligations The national Football League (LaLiga) was fined for offering an app which once per minute accessed the microphone of users' mobile phones in order to detect pubs screening… SPAIN ·aepd ·Art. 5, 7 Consent Supervisory Authorities Jun 11, 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 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 Video Surveillance Insurance Personal Data 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 ·Art. 5, 6 Personal Data Education Public Authority May 28, 2019
€400,000 SERGIC (Real Estate): Insufficient technical and organisational measures to ensure information security The CNIL based the penalty on two grounds: Lack of basic security measures and excessive data storage. As to the first, sensitive user documents uploaded by rental candidates… FRANCE ·CNIL ·Art. 5 Security Access Controls Healthcare 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
€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 Recipient May 21, 2019
€61,500 Payment service provider UAB MisterTango: Insufficient fulfilment of data breach notification obligations During an inspection, the Lithuanian Data Protection Supervisory Authority found that the controller processed more data than necessary to achieve the purposes for which he was a… LITHUANIA ·VDAI ·Art. 5, 32, 33 Notification Obligation Data Breaches Article 19 GDPR - Notification of Rectification, Erasure or Restriction May 16, 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 Public Sector May 9, 2019
€194 CZECH REPUBLIC DPA: Insufficient fulfilment of data subjects rights Information was not provided. UOOU ·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 ·Art. 32 Security Education Right of Access Apr 29, 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 Processors Data Breaches 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 Personal Data Processing Apr 17, 2019
€80,000 Company in the financial sector: Insufficient technical and organisational measures to ensure information security In an administrative decision dated 12 April 2019, the authority imposed a fine of 80,000 euros on a medium-sized financial services company. This company had failed to take the… GERMANY ·Art. 5, 32 ·Insufficient technical and organisational measures to ensure information security Integrity and Confidentiality Principle Anonymization Security Apr 12, 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 Integrity and Confidentiality Principle Healthcare Healthcare Apr 8, 2019
€34,375 Hungarian political party: Insufficient fulfilment of data breach notification obligations NAIH imposed a fine of HUF 11,000,000 (EUR 34,375) on an undisclosed Hungarian political party for failing to notify the NAIH and relevant individuals about a data breach, and… HUNGARY ·NAIH ·Art. 33, 34 Notification Obligation Data Breaches Notified Body Reporting and Notification Obligations Apr 5, 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
€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
€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
€2,000 PORTUGAL DPA: Insufficient fulfilment of information obligations Inexistence of signalization regarding the use of CCTV systems CNPD ·Art. 13 ·Insufficient fulfilment of information obligations Video Surveillance Supervisory Authorities Processing Agreement Mar 25, 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
€2,000 PORTUGAL DPA: Insufficient fulfilment of information obligations Inexistence of signalization regarding the use of CCTV systems CNPD ·Art. 13 ·Insufficient fulfilment of information obligations Video Surveillance Supervisory Authorities Processing Agreement Mar 19, 2019
€3,200 Unnamed financial institution: Insufficient fulfilment of data subjects rights The fine was imposed in relation to a data subject's request for data correction and erasure. NAIH levied a fine against an unnamed financial institution for unlawfully rejecting… HUNGARY ·NAIH ·Art. 5, 6, 13 +1 Retention Period Legitimate Interest Personal Data Mar 4, 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 Security Mar 1, 2019
€170,000 Bergen Municipality: Insufficient technical and organisational measures to ensure information security The incident relates to computer files with usernames and passwords to over 35000 user accounts in the municipality’s computer system. The user accounts related to both pupils in… NORWAY ·Datatilsynet ·Art. 5, 32 Security Education Public Authority Mar 1, 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 Education Public Authority Feb 28, 2019