GDPR Enforcement Tracker

This website contains a list and overview of fines and penalties which data protection authorities within the EU have imposed under the EU General Data Protection Regulation (GDPR, DSGVO). Our aim is to keep this list as up-to-date as possible. Since not all fines are made public, this list can of course never be complete, which is why we appreciate any indication of further GDPR fines and penalties.
CountryAuthorityDateFine [€]Controller/ProcessorQuoted Art.TypeSummaryInfos
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2018-12-094,800Betting placeArt. 13 GDPRInsufficient fulfilment of information obligationsVideo surveillance was not sufficiently marked and a large part of the sidewalk of the facility was recorded. Surveillance of the public space in this way, i.e. on a large scale by private individuals, is not permitted.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)Unknown-20181,800Kebab restaurantUnknownInsufficient legal basis for data processingCCTV was unlawfully used. No further information available.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)Unknown-2018UnknownRestaurantUnknownInsufficient legal basis for data processingCCTV was unlawfully used. No further information available.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2018-09-27300Private car ownerArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingA Dashcam was unlawfully used.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2018-12-202,200Private personArt. 5 (1) a) GDPR, Art. 5 (1) c) GDPR, Art. 6 (1) GDPR, Art. 13 GDPRInsufficient legal basis for data processingThe fine was imposed against a private person who was using CCTV at his home. The video surveillance covered areas which are intended for the general use of the residents of the multi-party residential complex, namely: parking lots, sidewalks, courtyard, garden and access areas to the residential complex; in addition, the video surveillance covered garden areas of an adjacent property. The video surveillance subject of the proceedings is therefore not limited to areas which are under the exclusive power of control of the controller. Video surveillance is therefore not proportionate to the purpose and not limited to what is necessary. The video surveillance records the hallway of the house and films residents entering and leaving the surrounding apartments, thereby intervening in their highly personal areas of life without the consent to record their image data. The video surveillance was not properly indicated.link
BELGIUM
BELGIUM
Belgian Data Protection Authority (APD)2019-05-282,000MayorArt. 5 (1) b) GDPR, Art. 6 GDPRVariousThe administrative fine was imposed for the misuse of personal data by a mayor for campaign purposes.link
BULGARIA
BULGARIA
Bulgarian Commission for Personal Data Protection (KZLD)2018-04-12500BankArt. 5 (1) b) GDPR, Art. 6 GDPRInsufficient legal basis for data processingA fine of 1000 BGN (or roughly 500 EUR) was imposed on a bank for calling a client for the unresolved bills of his neighbor. This provoked the client to evoke his right to be forgotten. After not receiving any answer from the bank he filed another motion, for which the bank did take action in the statutory period. Nonetheless, the client filed a complaint to KZLD. The infringement for which the bank was fined was for the processing of the client’s personal data was not linked to his consumer credit agreement. Since the purpose for which the data were processed was different from that communicated at the time of conclusion of the contract, the bank had, in the point of view of KZLD, to request additional consent from its client.link link
BULGARIA
BULGARIA
Bulgarian Commission for Personal Data Protection (KZLD)2019-02-2627,100Telecommunication service providerArt. 6 GDPR, Art. 5 (1) a) GDPRInsufficient legal basis for data processingRepeated registration of prepaid services without the knowledge and consent of the data subject Employees of the telecommunications provider have used personal data and registered the complainant with the company's prepaid service. The data subject had not signed the application and had not consented to the processing of his personal data for the stated purpose. There was also no other legal basis applicable. The signature of the application and the complainant own genuine application were not identical and the persons personal identification number was indicated, but the identity card number was not the complainants one.link
BULGARIA
BULGARIA
Bulgarian Commission for Personal Data Protection (KZLD)2019-01-17500BankArt. 6 GDPR, Art. 5 (1) a) GDPRInsufficient legal basis for data processingA bank gained personal data concernign a student wihtout a legal basis.link
BULGARIA
BULGARIA
Bulgarian Commission for Personal Data Protection (KZLD)2019-02-22500EmployerArt. 15 GDPRInsufficient fulfilment of data subjects rightsAn employee sent a request to his employer for access to personal data concerning him. The request was not answered in time and not in a complete way.link
CYPRUS
CYPRUS
Cyprian Data Protection CommissionerUnknown-20195,000State HospitalArt. 15 GDPRInsufficient fulfilment of data subjects rightsA 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 the controller. After investigating the case, an administrative fine of €5,000 was imposed on the hospital.link
CYPRUS
CYPRUS
Cyprian Data Protection CommissionerUnknown-201910,000NewspaperArt. 6 GDPRInsufficient legal basis for data processingThe publication of the newspaper, both in hard copy and in electronic form, allegedly involved inconvenience, unnecessary and unlawful detention of a citizen, and revealed the names and pictures of the two police investigators involved, as well as the photograph of a third police investigator. The Commissioner considered that the aim could be achieved by referring only to the initials of their name and/or their faces being blurred and/or publishing photographs drawn from a distant distance so that it was impossible to identify the persons, and these actions would not bring any change in the nature of the case.link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-01-10388EmployerArt. 6 GDPRInsufficient legal basis for data processingA 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 long after the termination of the employment relationship. The fine was imposed because the employer did not delete the information relating to the former employee.link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-02-041,165Car renting companyArt. 5 (1) a) GDPRInsufficient fulfilment of information obligations and insufficient legal basis for data processingA person who rented a car found out that the car was tracked via GPS by the renting company even though there was no information provided on the fact that the car is being tracked. The Czech Data Protection Authority found that there was no information provided in terms of Art. 13 GDPR and that Art. 6 (1) f) GDPR could not be the legal basis under the concrete circumstances. Due to that the UOOU found that there was a violation of Art. 5 (1) a) GDPR for which it imposed the fine.link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-02-28582UnknownArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityData was not processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ('integrity and confidentiality').link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-02-041,165Credit brokerageArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityData was not processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures ('integrity and confidentiality').link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2018-10-25388UnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsInformation was not provided.link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-02-26776UnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsInformation was not provided.link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-03-219,704UnknownArt. 5 (1) c) GDPR, Art. 5 (1) e) GDPRNon-compliance with general data processing principlesData 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 in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed ("storage limitation").link
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-05-133,105UnknownArt. 5 (1) a) GDPR, Art. 5 (1) b) GDPR, Art. 32 (1) GDPRlink
CZECH REPUBLIC
CZECH REPUBLIC
Czech Data Protection Auhtority (UOOU)2019-05-06194UnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsInformation was not provided.link
DENMARK
DENMARK
Danish Data Protection Authority (Datatilsynet)Tbd-2019160,000Taxa 4x35Art. 5(1) e) GDPRNon-compliance with general data processing principlesThe 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 names of its passengers from all its records after two years, the deletion did not include the rest of the ride records (about 8,873,333 taxi trips). Hence, the company continued to hold onto individual's phone numbers.  Please note: Since Danish law does not provide for administrative fines as in the GDPR (unless it is an uncomplicated case and the accused person consented), fines will be imposed by courts.link
DENMARK
DENMARK
Danish Data Protection Authority (Datatilsynet)2019-06-03200,850IDdesign A / SArt. 5 (1) e) GDPR, Art. 5 (2) GDPRNon-compliance with general data processing principlesThe fine was imposed as a result of an inspection carried out in autumn of 2018. IDdesign had processed personal data of approximately 385,000 customers for a longer period than necessary for the purposes for which they were processed. Additionally, the company had not established and documented deadlines for deletion of personal data in their new CRM system. The deadlines set for the old system were not deleted after the deadline for the information had been reached. Also, the controller had not adequately documented its personal data deletion procedures. Please note: Since Danish law does not provide for administrative fines as in the GDPR (unless it is an uncomplicated case and the accused person consented), fines will be imposed by courts.link
FRANCE
FRANCE
French Data Protection Authority (CNIL)2019-01-2150,000,000Google Inc.Art. 13 GDPR, Art. 14 GDPR, Art. 6 GDPR, Art. 4 GDPR, Art. 5 GDPRVariousThe 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 and 28th of May 2018 - immediately after the DSGVO became applicable. The complaints concerned the creation of a Google account during the configuration of a mobile phone using the Android operating system. The CNIL imposed a fine of 50 million euros for lack of transparency (Art. 5 GDPR), insufficient information (Art. 13 / 14 GDPR) and lack of legal basis (Art. 6 GDPR). The obtained consents had not been given "specific" and not "unambigous" (Art. 4 nr. 11 GDPR).link
FRANCE
FRANCE
French Data Protection Authority (CNIL)2019-05-28400,000SERGIC (Real Estate)Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 (including ID cards, health cards, tax notices, certificates issued by the family allowance fund, divorce judgments, account statements) were accessible online without any authentication procedure in place. Although the vulnerability was known to the company since March 2018, it was not finally resolved until September 2018. In addition, the company stored the documentation provided by candidates for longer than necessary. The CNIL took into account i.a. the seriousness of the breach (lack of due care in addressing vulnerability and the fact that the documents revealed very intimate aspects of users' lives), the size of the company and its financial standing.link
GERMANY
GERMANY
Data Protection Authority of Baden-Wuerttemberg2018-11-2120,000Knuddels.deArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityAfter a hacker attack in July personal data of approx. 330.000 users, including passwords and email addresses had been revealed.link
GERMANY
GERMANY
Data Protection Authority of Hamburg2018-12-175,000Kolibri Image Regina und Dirk Maass GbRArt. 28 (3) GDPRInsufficient data processing agreementPlease note: According to our information this fine has been withdrawn in the meantime. Kolibri Image had send a request to the Data Protection Authority of Hessen asking how to deal with a service provider who does not want to sign a processing agreement. After not answering Kolibri Image in more detail, the case was forwarded to the locally responsible Data Protection Authority of Hamburg. This Authority then fined Kolibri Image as controller for not having a processing agreement with the service provider. Kolibri Image has stated that they will challenge the decision in front of court since they are of the opinion that the service provider does not act as a processor.link link
GERMANY
GERMANY
Data Protection Authority of Baden-Wuerttemberg2019-XX-XX80,000UnknownArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityA company in the financial sector had improperly disposed personal data.link
GERMANY
GERMANY
Data Protection Authority of Sachsen-Anhalt2019-02-052,500Private personArt. 6 GDPR, Art. 5 GDPRInsufficient legal basis for data processingThe 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 which each recipient could read countless other recipients. The man was accused of ten offences between mid-July and the end of July 2018. According to the authority's letter, between 131 and 153 personal mail addresses were identifiable in his mailing list.link
GERMANY
GERMANY
Data Protection Authority of HamburgUnknown-201820,000UnknownArt. 83 (4) a) GDPR, Art. 33 (1) GDPR, Art. 34 (1) GDPRInsufficient fulfilment of data breach obligationsLate notification of a data breach and failure to notify the data subjects.Page 134 of the activity report of the Data Protection Commissioner of Hamburg, accessible under link
GERMANY
GERMANY
Data Protection Authority of SaarlandUnknown118UnknownArt. 6 GDPRInsufficient legal basis for data processingIllegal disclosure of personal data relating to a third party.link
GERMANY
GERMANY
Data Protection Authority of HamburgUnknown-2018500UnknownUnknownUnknownUnknownlink
GERMANY
GERMANY
Data Protection Authority of Berlin2019-03-##50,000N26Art. 6 GDPRInsufficient legal basis for data processingThe 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 that it had retained data relating to former customers in order to maintain a blacklist, a kind of warning file, so that it would not make a new account available to these persons. The bank initially justified this by stating that it was obliged under the German Banking Act to take security measures against customers suspected of money laundering. The Berlin supervisory authority judged this to be illegal. The authority argues that in order to prevent a new bank account from being opened, only those affected may be included in a comparison file who are actually suspected of money laundering or for whom there are other valid reasons for refusing a new bank account. The authority told a newspaper that the fine proceedings initiated against the bank had "not yet been legally concluded".Page 131 of the activity report of the Data Protection Commissioner of Berlin link link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-02-081,560BankArt. 5 (1) d) GDPRNon-compliance with general data processing principlesA 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 the time of contracting, the bank did not comply with the data subject's request to erase the data and continued to send SMS message to the incorrect telephone number. The fine represents 0.0016% of the annual profit of the bank.link link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-02-201,560Debt collectorArt. 5 (1) a) GDPR, Art. 5 (1) c) GDPRNon-compliance with general data processing principlesA 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 purposes he requested place of birth, mother’s maiden name and further details from the data subject. After the controller succeeded to identify the data subjects he refused to comply with the deletion request, arguing he is legally obliged to retain backup copies according to the Accountancy Act and internal policies. Since he did not properly inform about these policies, the NAIH held the controller breached the principle of transparency. The fine constitutes 0.0025% of the annual profit of the controller.link link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2018-12-183,200UnknownArt. 12 (4) GDPR, Art. 15 GDPR, Art. 18 (1) c) GDPR, Art. 13 GDPRInsufficient fulfilment of data subjects rights and insufficient fulfilment of information obligationsThe fine was imposed for (i) not providing a data subject with CCTV recordings, (ii) not retaining recordings for further use by the data subject, and (iii) not informing the data subject about his right to lodge a complaint to the supervisory authority.link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-02-283,200Mayor's Office of the city of KecdkemétArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingThe 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 of an organisation that it supervised reported a public interest complaint directly to it against his employer. After the organisation learned of the complaint, it requested details in order to investigate, and the local government accidentally revealed the complainant's name. The NAIH considered it an aggravating factor that as a result of the data breach, the organisation fired the person who made the report.link link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-03-043,200Unnamed financial institutionArt. 5 (1) b) GDPR, Art. 5 (1) c) GDPR, Art. 13 (3) GDPR, Art. 17 (1) GDPR, Art. 6 (4) GDRPInsufficient fulfilment of data subjects rightsThe 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 a customer’s request to have his phone number erased after arguing that it was in the company's legitimate interest to process this data in order to enforce a debt claim against the customer. In its decision, the NAIH emphasised that the customer’s phone number is not necessary for the purpose of debt collection because the creditor can also communicate with the debtor by post. Consequently, keeping the phone number of the debtor was against the principles of data minimisation and purpose limitation. As per the law, the assessed fine was based on 0.025% of the company's annual net revenue.link link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-04-0534,375Hugarian political partyArt. 33 (1) GDPR, Art. 33 (5) GDPR, Art. 34 (1) GDPRInsufficient fulfilment of data breach obligationsNAIH 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 failing to document the breach according to GDPR Article 33.5. As mandated by law, the fine was based on 4% of the party's annual turnover and 2.65 % of its anticipated turnover for the coming year. The breach was the result of a cyber attack by an anonymous hacker who accessed and disclosed information on the vulnerability of the organisation’s system – a database of more than 6,000 individuals – and the command used for the attack. The system was vulnerable to attack because of a redirection problem with the organisation's webpage. After the attacker published the command, even people with low IT knowledge were able to retrieve information from the database.link
ITALY
ITALY
Italian Data Protection Authority (Garante)2019-04-1750,000Italian political party Movimento 5 StelleArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityA 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 suffered a data breach during the summer 2017 that led the Italian data protection authority, the Garante, to require the implementation of a number of security measures, in addition to the obligation to update the privacy information notice in order to give additional transparency to the data processing activities performed.While the update of the privacy information notice was timely completed, the Italian data protection authority, raised its concerns as to the lack of implementation on the Rousseau platform of some of GDPR related security measures. It is worth it to mention that the proceeding initiated before May 2018, but the Italian data protection authority issued a fine under the GDPR since the Rousseau platform had not adopted security measures required by means of an order issued after the 25th of May 2018. Interestingly, the fine was not issued against the Movimento 5 Stelle that is the data controller of the platform, but against the Rousseau association that is the data processor.link
LITHUANIA
LITHUANIA
Lithuanian Data Protection Authority (VDAI)2019-05-1661,500Payment service provider UAB MisterTangoArt. 5 GDPR, Art. 32 GDPR, Art. 33 GDPRInsufficient technical and organisational measures to ensure information security and insufficient fulfilment of data breach obligationsDuring 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 controller. In addition, it became known that from 09 - 10 July 2018 payment data were publicly available on the internet due to inadequate technical and organisational measures. 9,000 payments with 12 banks from different countries were affected. According to the supervisory authority, a data breach notification pursuant to Art. 33 DSGVO would have been necessary. The controller did not report the Data Breach.link
MALTA
MALTA
Data Protection Commissioner of Malta2019-02-185,000Lands AuthorityArt. 5 GDPR, Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityAs a result of the lack of appropriate security measures on the Lands Authority website, over 10 gigabytes of personal data became easily accessible to the public via a simple google search. The majority of the leaked data contained highly-sensitive information and correspondence between individuals and the Authority itself. The Lands Authority chose not to appeal. In Malta, in the case of a breach by a public authority or body, the Data Protection Commissioner may impose an administrative fine of up to €25,000 for each violation and may additionally impose a daily fine of €25 for each day such violation persists.link
NORWAY
NORWAY
Norwegian Supervisory Authority (Datatilsynet)2019-03-XX170,000Bergen MunicipalityArt. 5 (1) f) GDPR, Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 the municipality’s primary schools, and to the employees of the same schools. Due to insufficient security measures, these files have been unprotected and openly accessible. The lack of security measures in the system made it possible for anyone to log in to the school’s various information systems, and thereby to access various categories of personal data relating to the pupils and employees of the schools. The fact that the security breach encompasses personal data to over 35 000 individuals, and that the majority of these are children, were considered to be aggravating factors. The municipality had also been warned several times, both by the authority and an internal whistleblower, that the data security was inadequate.link
POLAND
POLAND
Polish National Personal Data Protection Office (UODO)2019-03-26219,538Private company working with data from publicly available sourcesArt. 14 GDPRInsufficient fulfilment of information obligationsThe 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 Central Electronic Register and Information on Economic Activity, and processed the data for commercial purposes. The authority verified incompliance with the information obligation in relation to natural persons conducting business activity – entrepreneurs who are currently conducting such activity or have suspended it, as well as entrepreneurs who conducted such activity in the past. The controller fulfilled the information obligation by providing the information required under Art. 14 (1) – (3) of the GDPR only in relation to the persons whose e-mail addresses it had at its disposal. In case of the remaining persons the controller failed to comply with the information obligation – as it explained in the course of the proceedings – due to high operational costs. Therefore, it presented the information clause only on its website. According to the UODO this is not sufficient.link
POLAND
POLAND
Polish National Personal Data Protection Office (UODO)2019-04-2512,950Sports associationArt. 6 GDPRInsufficient legal basis for data processingOne 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 addresses and PESEL numbers. Meanwhile, there is no legal basis for such a wide range of data on judges to be available on the Internet. By making them public, the administrator posed a potential risk of their unauthorized use, e.g. to impersonate them for the purpose of borrowing or other obligations. Although the association itself noticed its own error, as evidenced by the notification of a personal data protection breach to the President of the PDPA, the fact that attempts to remove it were ineffective determined the imposition of a penalty. When determining the amount of the fine (PLN 55,750.50), the President of UODO also took into account, among others, the duration of the infringement and the fact that it concerned a large group of persons (585 judges). It concluded that although the infringement was finally removed, it was of a serious nature.However, when imposing a penalty, the President of the Office of Competition and Consumer Protection also took into account mitigating circumstances, such as good cooperation between the controller and the supervisory authority or lack of evidence that damage had been caused to the persons whose data had been disclosed.link link
PORTUGAL
PORTUGAL
Portuguese Data Protection Authority (CNPD)2018-07-17400,000Public HospitalArt. 5 (1) f) GDPR, Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityInvestigation revealed that the hospital’s staff, psychologists, dietitians and other professionals had access to patient data through false profiles. The profile management system appeared deficient – the hospital had 985 registered doctor profiles while only having 296 doctors. Moreover, doctors had unrestricted access to all patient files, regardless of the doctor’s specialty.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)Unknown-20185,000VODAFONE ESPANA, S.A.U.Art. 5 (1) d) GDPRNon-compliance with general data processing principlesThe spanish telecommunications and informations agancy (SETSI) decided Vodafone had to reimburse a customer for costs he was wrongfully charged for. Nevertheless, Vodafone reported personal data of this respective customer to a solvency registry (BADEXCUG). The AEPD found this behaviour violated the principle of accuracy.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-06-11250,000Professional Football League (LaLiga)Art. 5 (1) a), Art. 7 (3) GDPRInsufficient fulfilment of information obligationsThe 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 football matches without paying a fee. In the opinion of the AEPD LaLiga did not adequately inform the users of the app about this practice. Furthermore, the app did not meet the requirements for withdrawal of consent.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)Unknown60,000Debt collecting agancy (GESTIÓN DE COBROS, YO COBRO SL)Art. 5 (1) f) GDPRInsufficient legal basis for data processingAfter the claimant did alledgedly not pay back a microcredit to an online credit agany, the claim was assigned to the debt collecting agancy. Subsequently, the latter startet sending emails not only to email addresses provided by the claimant but also to an institutional email address of his workplace accessible by any co-worker which was never provided by the claimant.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)Unknown27,000VODAFONE ESPANA, S.A.U.Art. 5 (1) d) GDPRInsufficient fulfilment of data subjects rightsAlthough the complainant (a former Vodafone customer) had requested Vodafone to delete his data in 2015 and this request had been confirmed by the company, he received more than 200 SMS from the company from 2018 onwards. Following Vodafone's statement, this happened because the complainant's mobile phone number was erroneously used for testing purposes and accidentally appeared in various customer files belonging to other customers than the complainant. Since the company agreed to both payment and admission of responsibility the fine was reduced in accordance with Spanish administrative law to EUR 27k.link
GERMANY
GERMANY
Data Protection Authority of Baden-Wuerttemberg2019-05-091,400Police OfficerArt. 6 GDPRInsufficient legal basis for data processingThe 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 via the Central Traffic Information System (ZEVIS) of the Federal Motor Transport Authority. Using the personal data obtained in this way, he then carried out a so-called SARS enquiry with the Federal Network Agency, in which he asked not only for the personal data of the injured parties but also for the home and mobile phone numbers stored there. Using the mobile phone number obtained in this way, the police officer contacted the injured party by telephone - without any official reason or consent given by the injured party. Through the ZEVIS and SARS enquiry for private purposes and the use of the mobile phone number obtained in this way for private contact, the police officer has processed personal data outside the scope of the law on his own authority. This infringement is not attributable to the police officer's department, since he did not commit the act in the exercise of his official duties, but exclusively for private purposes. The prohibition of punishment under § 28 LDSG, according to which the sanctions of the DSGVO cannot be imposed on public bodies, does not apply in the present case, since it was neither a case of misconduct attributable to the authority nor is the person concerned to be classified as a separate public body within the meaning of § 2 (1) or (2) LDSG in the case of the acts in question.link
FRANCE
FRANCE
French Data Protection Authority (CNIL)2019-06-1320,000Employer UNIONTRAD COMPANYArt. 5 (1) c) GDPR, Art. 12 GDPR, Art. 13 GDPR, Art. 32 GDPRInsufficient legal basis for data processingBetween 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 rules to be observed when installing cameras in the workplace, in particular, that employees should not be filmed continuously and that information about the data processing has to be provided. In the absence of satisfactory measures at the end of the deadline set in the formal notice, the CNIL carried out a second audit in October 2018 which confirmed that the employer was still breaching data protection laws when recording employees with CCTV. When determening the amount of the fine, the CNLIN took into account the size (9 employees) and the financial situation of the company, which presented a negative net result in 2017 (turnover of 885,739 EUR in 2017 and a negative net result of 110,844 EUR), to retain a dissuasive but proportionate administrative fine.link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-04-179,400UnknownArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingA 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.link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-04-051,900UnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsThe data controller did not fulfil the data subject's access request.link
BULGARIA
BULGARIA
Data Protection Commision of Bulgaria (KZLD)2019-04-08510Medical centersArt. 5 (1) a) GDPR, Art. 9 (1) GDPR, Art. 9 (2) GDPR, Art. 6 (1) GDPRInsufficient legal basis for data processingThe 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 GP. The medical centre used a software to generate a registration form for change of GP which was submitted to the Regional Health Insurance Fund and then to another medical centre, which subsequently also unlawfully processed the personal data of G.B.link
BULGARIA
BULGARIA
Data Protection Commision of Bulgaria (KZLD)2019-03-265,100A.P. EOODArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingThe 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 preparing an Employment Contract, while he was in prison.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)Unknown-201960,000ENDESA (energy supplyer)Art. 5 (1) f) GDPRInsufficient legal basis for data processingThe complainant's bank account was charged by ENDESA, the beneficiary of which was a third party, who had been convicted under criminal law and imposed with a two-year restraining order regarding the claimant, her domicile and work. Instead amending the contract details as requested by the claimant ENDESA deleted her data erroneously and fillid in the data of the third party. The AEPD found the disclosure of the claimant's data to the third party was a severe violation of the principle of confidentiality.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-06-27130,000UNICREDIT BANK SAArt. 25 (1) GDPR, Art. 5 (1) c) GDPRInsufficient technical and organisational measures to ensure information securityThe 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, and (2) the integration the necessary safeguards) resulting in the online-disclosure of IDs and addresses (interla/external transactions) of 337,042 data subjects to their respective beneficiary (between 25.05.2018 -10.12.2018).link
UNITED KINGDOM
UNITED KINGDOM
Information Commissioner (ICO)2019-07-08204,600,000British AirwaysArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityPlease note: This fine is not final but will be decided on when the company and other involved supervisory authorities of other member states have made their representations. The ICO issued a notice of its intention to fine British Airways £183.39M for GDPR infringements which likely involve a breach of Art. 32 GDPR. The proposed fine relates to a cyber incident notified to the ICO by British Airways in September 2018. This incident in part involved user traffic to the British Airways website being diverted to a fraudulent site. Through this false site, customer details were harvested by the attackers. Personal data of approximately 500,000 customers were compromised in this incident, which is believed to have begun in June 2018. The ICO’s investigation has found that a variety of information was compromised by poor security arrangements at the company, including log in, payment card, and travel booking details as well name and address information.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-07-0215,000WORLD TRADE CENTER BUCHAREST SAArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 BUCHAREST SA was photographed by unauthorized people outside the company, which led to the disclosure of the personal data of some clients through online publication. The operator of WORLD TRADE CENTER BUCHAREST SA has been sanctioned because it has not taken steps to ensure that data is not disclosed to unauthorized parties.link
UNITED KINGDOM
UNITED KINGDOM
Information Commissioner (ICO)2019-07-09110,390,200Marriott International, IncArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityPlease note: This fine is not final but will be decided on when the company and other involved supervisory authorities of other member states have made their representations. The ICO issued a notice of its intention to fine Marriott International Inc which relates to a cyber incident which was notified to the ICO by Marriott in November 2018.GDPR infringements are likely to involve a breach of Art. 32 GDPR. A variety of personal data contained in approximately 339 million guest records globally were exposed by the incident, of which around 30 million related to residents of 31 countries in the European Economic Area (EEA). Seven million related to UK residents. It is believed the vulnerability began when the systems of the Starwood hotels group were compromised in 2014. Marriott subsequently acquired Starwood in 2016, but the exposure of customer information was not discovered until 2018. The ICO’s investigation found that Marriott failed to undertake sufficient due diligence when it bought Starwood and should also have done more to secure its systems.link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-05-2392,146Organizer of SZIGET festival and VOLT festivalArt. 6 GDPR, Art. 5 (1) b) GDPR, Art. 13 GDPRInsufficient legal basis for data processing and non-compliance with general data processing principlesThe 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 processing was not fully provided to data subjects.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-07-053,000LEGAL COMPANY & TAX HUB SRLArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 to unauthorized disclosure and unauthorized access to the personal data of people who have made transactions received by the avocatoo.ro website (name, surname, mailing address, email, phone, job, details of transactions made), due to publicly accessible documents between 10th of December 2018 and 1st of February 2019. The National Supervisory Authority applied the sanction following a notification dated 12th of October 2018 indicating that a set of files regarding the details of the transactions received by the avocatoo.ro website which contained the name, surname, address correspondence, email, telephone, job and details of transactions made, was publicly accessible through two links.link
THE NETHERLANDS
THE NETHERLANDS
Dutch Supervisory Authority for Data Protection (AP)2019-06-18460,000Haga HospitalArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 Protection Authority. This investigation followed when it appeared that dozens of hospital staff had unnecessarily checked the medical records of a well-known Dutch person. To force the hospital to improve the security of patient records, the AP simultaneously imposes an order subject to a penalty. If the Haga Hospital has not improved security before 2nd of October 2019, the hospital must pay 100,000 EUR every two weeks, with a maximum of 300,000 EUR. The Haga Hospital has meanwhile indicated to take measures.link
FRANCE
FRANCE
French Data Protection Authority (CNIL)2019-07-25180,000ACTIVE ASSURANCES (car insurer)Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityLarge amount of customer accounts, clients' documents (including copies of driver's licences, vehicle registration, bank statements and documents to determine whether a person had been the subject of a licence withdrawal) and data were easily accesible online. The CNIL, between others, critizised the password management (unauthorized access was possible without any authentication).link
GREECE
GREECE
Hellenic Data Protection Authority (HDPA)2019-07-30150,000PWC Business SolutionsArt. 5 (1) GDPR, Art. 5 (2) GDPR, Art. 6 (1) GDPR, Art. 13 (1) c) GDPR, Art. 14 (1) c) GDPRInsufficient legal basis for data processing and insufficient fulfilment of information obligationsThe 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 carry out acts directly linked to the performance of employment contracts, compliance with a legal obligation to which the controller is subject and the smooth and effective operation of the company, as its legitimate interest. In addition, the company gave employees the false impression that it was processing their personal data under the legal basis of consent, while in reality it was processing their data under a different legal basis. This was in violation of the principle of transparency and thus in breach of the obligation to provide information under Articles 13(1)(c) and 14(1)(c) of the GDPR. Lastly, in violation of the accountability principle, the company failed to provide the HDPA with evidence that it had carried out a prior assessment of the appropriate legal bases for processing employee personal datalink
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-10-172,500UTTIS INDUSTRIES SRLArt. 12 GDPR, Art. 13 GDPR, Art. 5 (1) c) GDPR, Art. 6 GDPRInsufficient fulfilment of information obligationsThe 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 surveillance system, which they have been operating since 2016. And because he made the disclosure of the CNP of the employees, by displaying the Report for the training of the authorized ISCIR personnel for the year 2018 to the company notifier and could not prove the legality of the processing of the CNP, by disclosure, according to Art. 6 GDPR.link
SWEDEN
SWEDEN
Data Protection Authority of Sweden2019-08-2018,630School in SkellefteåArt. 5 (1) c) GDPR, Art. 9 GDPR, Art. 35 GDPR, Art. 36 GDPRInsufficient legal basis for data processingA 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 attendance of students. Even though, in general, data processing for the purpose of monitoring attendance is possible doing so with facial recognition is disproportioned to the goal to monitor attendance. The supervisory authority is of the opinion that biometric data of students was processed which is why Art. 9 GDPR is applicable. Additionally, the authority argued that consent can not be applied since students and their guardians cannot freely decide if they/their children want to be monitored for attendance purposes. When examining if the school board can rely on any of the exemptions listed in Art. 9 (2), the supervisory authority found that this was not the case. The supervisory authority also found that there was a case of a processing activity with high risks since new technology was used to process sensitive personal data concerning children who are in a dependency position to the high school board and due to camera surveillance being used in the students everyday environment. In the view of the authority, the school board was not able to demonstrate compliance with Art. 35 GDPR and that the school board was required to consult the authority in accordance with Art. 36 (1) GDPR.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2019-08-XX50,000Company in the medical sectorArt. 13 GDPR, Art. 37 GDPRInsufficient fulfilment of information obligations and breach of duty to appoint an DPOThe (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.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2019-07-XX11,000Private person (soccer coach)Art. 6 GDPRInsufficient legal basis for data processingThe fine was imposed on a soccer coach who had secretly filmed female players while they were naked in the shower cubicle for years.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-08-1660,000AVON COSMETICSArt. 6 GDPRInsufficient legal basis for data processingA 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 of claims, preventing him from working with his bank. As a result, a third party fraudulently used the consumers personal data.link
BULGARIA
BULGARIA
Data Protection Commision of Bulgaria (KZLD)2019-08-282,600,000National Revenue AgencyArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityLeakage 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 data concerning about 6 million persons was illegally accessible.link
BULGARIA
BULGARIA
Data Protection Commision of Bulgaria (KZLD)2019-08-28511,000DSK BankArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityLeakage 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 records relating to over 33000 bank customers including personal data such as names, citizenships, identification numbers, adresses, copies of identity cards and biometric data.link
LATVIA
LATVIA
Data State Inspectorate (DSI)2019-08-267,000Online ServicesArt. 17 GDPRInsufficient fulfilment of data subjects rightsA 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 all his personal data, in particular his/her mobile phone number, which the merchant had received as part of an order. Nevertheless, the merchant repeatedly sent advertising messages by SMS to the data subjects mobile phone number.link
HUNGARY
HUNGARY
Hungarian National Authority for Data Protection and the Freedom of Information (NAIH)2019-06-2515,150UnknownArt. 33 GDPRInsufficient fulfilment of data breach obligationsThe data controller did not fulfil its data breach obligations when a flash memory with personal data was lost.link
NORWAY
NORWAY
Norwegian Supervisory Authority (Datatilsynet)2019-04-29203,000Oslo Municipal Education DepartmentArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityFine 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 insufficient technical and organizational measures to protect information security, unauthorized persons were able to log in as authorized users and gain access to personal data about students, legal representatives and employees.link
PORTUGAL
PORTUGAL
Portuguese Data Protection Authority (CNPD)2019-02-0520,000UnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsDenial of the right to access recorded phone calls by the Data Subjectlink
PORTUGAL
PORTUGAL
Portuguese Data Protection Authority (CNPD)2019-03-252,000UnknownArt. 13 GDPRInsufficient fulfilment of information obligationsInexistence of signalization regarding the use of CCTV systemslink
GERMANY
GERMANY
Data Protection Authority of Berlin2019-09-19195,407Delivery HeroArt. 15 GDPR, Art. 17 GDPR, Art. 21 GDPRInsufficient fulfilment of data subjects rightsAccording 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 subjects had not been active on the company's delivery service platform for years - in one case even since 2008. In addition, eight former customers had complained about unsolicited advertising e-mails from the company. A data subject who had expressly objected to the use of his data for advertising purposes nevertheless received further 15 advertising e-mails from the delivery service. In further five cases, the company did not provide the data subjects with the required information or only after the Berlin data protection officer had intervened.link
POLAND
POLAND
Polish National Personal Data Protection Office (UODO)2019-09-10644,780Morele.netArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe 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 unauthorised access to the personal data of 2.2 million people.link
BELGIUM
BELGIUM
Belgian Data Protection Authority (APD)2019-09-1910,000MerchantArt. 5 (1) c) GDPRNon-compliance with general data processing principlesThe 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 investigation revealed that the merchant required access to personal data located on the eID, including the photo and barcode which is linked to the data subject's identification number.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)Unknown12,000RestaurantArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingA restaurant wanted to impose disciplinary sanctions on an employee using images from a mobile phone video which was recorded by another employee in the restaurant for evidence purposeslink
GREECE
GREECE
Hellenic Data Protection Authority (HDPA)2019-10-07200,000Telecommunication Service ProviderArt. 5 (1) c) GDPR, Art. 25 GDPRNon-compliance with general data processing principlesA 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.link
GREECE
GREECE
Hellenic Data Protection Authority (HDPA)2019-10-07200,000Telecommunication Service ProviderArt. 21 (3) GDPR, Art. 25 GDPRNon-compliance with general data processing principlesInappropriate technical measures resulted in the data of 8,000 customers not being deleted upon request.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-10-09150,000Raiffeisen Bank SAArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityRaiffeisen 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 WhatsApp and then returned the result to Vreau Credit using the same means of communication.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-10-0920,000Vreau Credit SRLArt. 32 GDPR, Art. 33 GDPRInsufficient technical and organisational measures to ensure information securityRaiffeisen 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 WhatsApp and then returned the result to Vreau Credit using the same means of communication.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-10-0130,000Vueling AirlinesArt. 5 GDPR, Art. 6 GDPRInsufficient legal basis for data processingThe 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 they want to browse its website. In other words, it was not possible to browse the Vueling page without accepting their cookies. AEDP issued a sanctioning resolution for the amount of 30,000 euros, which could be reduced to 18,000 for immediate payment.link
CYPRUS
CYPRUS
Cyprian Data Protection Commissioner2019-XX-XX14,000DoctorArt. 5 GDPR, Art. 6 GDPRInsufficient legal basis for data processingA 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 the controller. After investigating the case, an administrative fine of €5,000 was imposed on the hospital.link
ROMANIA
ROMANIA
Romanian National Supervisory Authority for Personal Data Processing (ANSPDCP)2019-09-269,000Inteligo Media SAArt. 5 (1) a) GDPR, Art. 6 (1) a) GDPRInsufficient legal basis for data processingAs 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 information letters via e-mail (opt-out). Without any action, the user was automatically sent information letters via e-mail. This did not fulfil the requirements for a GDPR-compliant consent.link
SLOVAKIA
SLOVAKIA
Slovak Data Protection OfficeUnknownUnknownUnknownArt. 15 GDPRInsufficient fulfilment of data subjects rightsA Data Controller failed to comply with data subject´s request to access his/her personal data processed by audio recordings.link
SLOVAKIA
SLOVAKIA
Slovak Data Protection OfficeUnknownUnknownUnknownArt. 5 (1) f) GDPR, Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityDocuments containing personal data were disposed of in the area of the municipal garbage dump.link
SLOVAKIA
SLOVAKIA
Slovak Data Protection OfficeUnknownUnknownUnknownArt. 5 (1) f) GDPR, Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityViolation of information security measures (no further information available at the moment)link
SLOVAKIA
SLOVAKIA
Slovak Data Protection OfficeUnknownUnknownUnknownArt. 5 (1) a) GDPR, Art. 6 (1) a) GDPRInsufficient legal basis for data processingPersonal data have been unlawfully published on the website of a city within the framework of fulfilling its disclosure obligation under the Freedom of Information Act. However, the Data Protection Authority stated that the City had published the personal data in violation of the law and without the consent of the person concerned.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-10-1660,000Xfera Moviles S.A.Art. 5 GDPR, Art. 6 GDPRInsufficient legal basis for data processingXfera 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 requested that the processing be discontinued.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-10-168,000Iberdrola ClientesArt. 31 GDPRLack of cooperation with the supervisory authorityIberdrola 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 solvency list. As a result, the AEPD requested that Iberdola Clientes provide information about the possibility of adding the person's data to the solvency list to which the company did not respond. This lack of cooperation with the AEPD was a violation of Article 31 of the GDPR.link
SLOVAKIA
SLOVAKIA
Slovak Data Protection OfficeUnknown40,000Slovak TelekomArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe controller did not take adequate security measures when processing personal data, thereby breaching the obligation to protect the processed personal data.link
AUSTRIA
AUSTRIA
Austrian Data Protection Authority (dsb)2019-10-2318,000,000Austrian PostArt. 5 (1) a) GDPR, Art. 6 GDPRInsufficient legal basis for data processingThe Austrian Post had created profiles of more than three million Austrians, which included information about their home addresses, personal preferences, habits and possible party affinity - which were subsequently resold, for example to political parties and companies. (In the case, also a civil court judgement about compensation claims at a value of 800 € has already been issued: link )link
POLAND
POLAND
Polish National Personal Data Protection Office (UODO)2019-10-189,380Major of Aleksandrów KujawskiArt. 28 GDPRInsufficient data processing agreementNo 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 Aleksandrów Kujawski. For this reason, a fine of 40.000 PLN (9400 EUR) was imposed on the mayor of the city.link
GERMANY
GERMANY
Data Protection Authority of Berlin2019-10-3014,500,000Deutsche Wohnen SEArt. 5 GDPR, Art. 25 GDPRNon-compliance with general data processing principlesThe company used an archiving system for the storage of personal data of tenants that did not provide for the possibility of removing data that was no longer required. Personal data of tenants were stored without checking whether storage was permissible or even necessary. It was therefore possible to access personal data of affected tenants which had been stored for years without this data still serving the purpose of its original collection. This involved data on the personal and financial circumstances of tenants, such as salary statements, self-disclosure forms, extracts from employment and training contracts, tax, social security and health insurance data as well as bank statements. In addition to sanctioning this structural violation, the Berlin data protection commissioner imposed further fines of between 6,000 and 17,000 euros on the company for the inadmissible storage of personal data of tenants in 15 specific individual cases. See the separate entry.link
GERMANY
GERMANY
Data Protection Authority of Berlin2019-10-30UnknownDeutsche Wohnen SEArt. 5 GDPRNon-compliance with general data processing principlesIn 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 fines of between 6,000 and 17,000 euros on the company for the inadmissible storage of personal data of tenants in 15 specific individual cases.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-10-2536,000VODAFONE ESPANA, S.A.U.Art. 5 GDPR, Art. 6 GDPRInsufficient legal basis for data processingThe 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, Vodafone España proceeded to providing him services and seeking payment from him, so Vodafone España had processed the claimant's personal data without his consent.link
GERMANY
GERMANY
Data Protection Authority of Baden-Wuerttemberg2019-XX-XX80,000UnknownArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityIn a digital publication, health data was accidentally published due to inadequate internal control mechanisms.link
POLAND
POLAND
Polish National Personal Data Protection Office (UODO)2019-10-1647,000ClickQuickNowArt. 5 GDPRNon-compliance with general data processing principlesThe 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 and organisational measures that allow the simple and effective withdrawal of consent to the processing of personal data and the exercise of the right to request the erasure of personal data.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-11-07900TODOTECNICOS24H S.L.Art. 13 GDPRInsufficient fulfilment of information obligationsTODOTECNICOS24H had collected personal data without providing accurate information about data collection in its data protection declaration pursuant to Article 13 of the GDPR.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-XX-XX12,000Madrileña Red de GasArt. 32 GDPRInsufficient technical and organisational measures to ensure information securityThe gas company did not have appropriate measures in place to verify the identity of the data subject. The person who filed the complaint alleges that the company e-mailed his information to a third party in response to a request.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-11-061,500Cerrajero OnlineArt. 13 GDPRInsufficient fulfilment of information obligationsThe company had collected personal data without providing accurate information about data collection in its data protection declaration pursuant to Article 13 of the GDPR.link
SPAIN
SPAIN
Spanish Data Protection Authority (aepd)2019-10-316,000Jocker Premium InvexArt. 6 GDPRInsufficient legal basis for data processingAfter 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 address were only communicated to the public administration.link
THE NETHERLANDS
THE NETHERLANDS
Dutch Supervisory Authority for Data Protection (AP)2019-10-31900,000UWV (Dutch employee insurance service provider)Art. 32 GDPRInsufficient technical and organisational measures to ensure information securityAs the UWV (the Dutch employee insurance service provider - "Uitvoeringsinstituut Werknemersverzekeringen") did not use multi-factor authentication when accessing the online employer portal, security was inadequate. Employers and health and safety services were able to collect and display health data from employees in an absence system.link
PORTUGAL
PORTUGAL
Portuguese Data Protection Authority (CNPD)2019-03-192,000UnknownArt. 13 GDPRInsufficient fulfilment of information obligationsInexistence of signalization regarding the use of CCTV systemslink