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Summary

The Czech DPA (UOOU) imposed a fine against a company for processing personal data without a sufficent legal basis. Several individuals were contacted by the sales staff of the controller for advertising purposes. The data subjects had used the services of the sales staff in the past (until around 2016) to conclude insurance or financial contracts. However, at that time, the sales staff were working for a different company with which they had concluded an agency contract. The DPA notes that on the one hand the use of the personal data known to the representatives from their previous activity constitutes a breach of the contract concluded with the previous company, and on the other hand no legal basis existed for the further processing of the data for advertising purposes in favour of the controller.