Sułkowice Cultural Center – €529 Fine (Poland, 2022)
General GDPR enforcement action
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The Polish DPA fined the Sułkowice Cultural Center €529 for failing to protect personal data during a breach. The center allowed a processor to handle sensitive employee data without a written agreement or proper checks. This case shows that organizations must have clear contracts and safeguards when outsourcing data processing.
What happened
The Sułkowice Cultural Center failed to have a written agreement with a processor handling personal data.
Who was affected
Thirty individuals, including employees of the Sułkowice Cultural Center, were affected by the data breach.
What the authority found
The Polish DPA found that the center did not comply with GDPR requirements for data processing agreements and safeguards.
Why this matters
This case highlights the necessity for organizations to have formal agreements with any third parties processing personal data. It serves as a warning to businesses about the risks of inadequate data protection practices.
GDPR Articles Cited
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National Law Articles
In May 2020, the Polish DPA received a notification of personal data breach caused by the Sułkowice Cultural Centre (the controller). The data breach affected 30 persons, including employees of the controller. The DPA initiated an investigation, in which it found that the controller entrusted the processing of personal data to an entity (the processor) without entering into a written data processing agreement. Moreover, they did not verify whether the processor provides sufficient guarantees of the implementation of appropriate technical and organisational measures in accordance with the GDPR. The processor was responsible for keeping accounting books and records as well as preparing reports. Therefore, they were entrusted with the processing of employee's and former employee's personal data, including names, dates of birth, bank account numbers, residence addresses, personal identification number (PESEL), email addresses, data on earnings and/or property, the mother's family names, series and numbers of ID cards, telephone numbers, and health data. Since the Polish DPA was not able to obtain information on any contract concluded between the controller and the processor with regards to the above-discussed processing operations, the DPA initiated ex officio administrative proceesings against the controller. First, the Polish DPA reiterated Article 28(1) GDPR, which prescribes that sufficient guarantees to implement appropriate technical and organisational measures must exist whenever the controller mandates data processing activities to be carried out on their behalf. Moreover, in line with Article 28(3) GDPR, a data processing agreement must be concluded between the controller and the processor, which stipulates the conditions of processing. Additionally, Article 28(9) GDPR requires the agreement to be in writing, including in electronic form. Second, the DPA clarified the roles of the entities involved in processing. As the employer and main administrator, the C
Related Enforcement Actions (0)
No other enforcement actions found for Sułkowice Cultural Center in PL
This is the only recorded action for this entity in this jurisdiction.
Details
Fine Date
7 September 2022
Authority
Urząd Ochrony Danych Osobowych
Fine Amount
€529
About this data
Cite as: Cookie Fines. Sułkowice Cultural Center - Poland (2022). Retrieved from cookiefines.eu
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