- Enforcing jurisdiction
- Norway · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
Datatilsynet – Complaint Upheld (Norway, 2020)
Privacy enforcement record
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Norway's data protection authority upheld a complaint against Arendal municipality for improperly using a digital form to survey bullying in schools. The municipality had no legal grounds to process the data, which means they must delete the collected information. This case is important because it shows that local governments must follow strict rules when handling personal data.
What happened
The data protection authority found that Arendal municipality lacked legal grounds for processing personal data in a bullying survey.
Who was affected
Parents and students involved in the bullying survey conducted by Arendal municipality.
What the authority found
The authority ruled that the municipality must delete all personal data related to the survey due to a lack of legal basis.
Why this matters
This decision highlights the need for municipalities to ensure they have valid reasons for processing personal data, reinforcing compliance with data protection laws.
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Entities Involved
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A parent submitted a complaint to the DPA on the municipality's use of a digital form to survey bullying behaviour at local schools. The DPA concluded in their investigations that the municipality lacked legal grounds for the processing cf. Article 6(1)(c), as they didn't believe the processing was "required" to achieve the goals of The Education Act Chapter 9A. Consequently, the municipality had to delete all personal data related to this processing, cf. Article 17(1)(d). The DPA also found that the municipality were in breach of the principles of lawfulness, fairness and transparency, cf. Article 5(1)(a), and accuracy, cf. Article (5)(1)(d), they hadn't recorded the processing activity as required in Article 30, hadn't conducted a risk assessment as per Article 32(2) or a Data Protection Impact Assessment as per Article 35(1) cf. 35(7) cf. the DPA's list over processing activities requiring a DPIA. Arendal municipality opposed this decision, however, following a review, the DPA continued to upheld it. The case was then forwarded to the Privacy Appeals Board, who concluded that the municipality had indeed sufficient legal grounds, however had other shortcomings that need to be resolved before further processing can take place, including: - conduct a DPIA cf. Article 35 - clearly inform students cf. Article 12 that a) it's voluntary to participate in the survey cf. Article 13(2)(f), and b) that their responses can be shared with individuals they name in their response cf. Article 15 - fulfill the other requirements as per the GDPR, including the fundamental principles for processing personal data cf. Article 5(1) and data subjects' rights cf. Chapter III - record the processing activity as per Article 30 - create written routines and other necessary documentation to ensure sufficient internal controls Did Arendal municipality (and the schools) have legal grounds for processing the personal data in the digital form, cf. Article 6(1)(c) cf. The Education Act Chapt
Outcome
Complaint Upheld
A data subject complaint that was upheld by the DPA.
Related Enforcement Actions (3)
Other enforcement actions involving Datatilsynet in NO
Complaint Upheld
Details
Decision Date
9 November 2020
Authority
Datatilsynet (Norway)
About this data
Cite as: Cookie Fines. Datatilsynet - Norway (2020). Retrieved from cookiefines.eu
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