Luxembourg

Unknown

15,400 €

GDPR enforcement action by National Commission for Data Protection (CNPD) on 2021-10-27.

Rank · Sector

#40

of 218 in Not assigned

Rank · Luxembourg

of 34

Rank · All fines

#1,167

of 3,050

Case details

Authority: National Commission for Data Protection (CNPD)
Date: 2021-10-27
Controller / Processor: Unknown
Sector: Not assigned
Quoted Articles: Art. 38 (1), (3) GDPR, Art. 39 (1) a), b) GDPR
Type of violation: Insufficient involvement of data protection officer

Summary

The Luxembourg DPA has imposed a fine of EUR 15,400 on a company. According to the DPA, the controller failed to involve the data protection officer in all matters related to the protection of personal data. In addition, contrary to the requirements of the GDPR, the data protection officer did not report directly to the highest management level; instead, there were two levels of hierarchy in between.
Also, the controller did not have a data protection control plan in place to demonstrate that the data protection officer was performing their duties appropriately.

Open original source Links to the regulator's original publication or another source.