Danish Municipalities – Order (Denmark, 2026)
General GDPR enforcement action
This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.
Danish municipalities were ordered by the Datatilsynet to improve their understanding of data protection when using Google services for schools. This matters because it shows that schools must be careful when choosing service providers to ensure they comply with data protection rules.
What happened
The municipalities were found to not fully understand their responsibilities when using Google Chromebooks and Google Workspace for Education.
Who was affected
Students and staff in primary and lower secondary schools using Google services.
What the authority found
The authority highlighted that the municipalities did not adequately fulfill their responsibilities as data controllers when engaging Google as a processor.
Why this matters
This case serves as a reminder for schools to thoroughly vet their service providers and ensure compliance with data protection laws.
GDPR Articles Cited
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Entities Involved
The case concerned the use of Google Chromebooks and Google Workspace for Education by 51 Danish municipalities in primary and lower secondary schools. The municipalities acted as controllers, while Google Cloud EMEA Limited (Ireland) acted as the primary data processor and Google relied on a complex chain of sub-processors. Background Given the sensitivity of the processing and the complexity of the processing chain, the Danish Data Protection Authority (Datatilsynet) initiated an extensive supervisory investigation known as the “Chromebook Case Complex.” This decision forms part of that investigation and concerns the use of Google software in schools, focusing on whether the data controllers adequately understood and fulfilled their responsibilities when engaging Google as a processor, including identifying the relevant sub-processors and ensuring their compliance with applicable data protection rules. In July 2024, Datatilsynet informed KL ([https://www.kl.dk/ Kommunernes Landsforening]), the national association of municipalities, acting as representative for the controllers, that it would seek an opinion from the European Data Protection Board (EDPB) on the obligations of data controllers when using processors and sub-processors, particularly regarding documentation of processing structures. [https://www.edpb.europa.eu/system/files/2024-10/edpb_opinion_202422_relianceonprocessors-sub-processors_en.pdf The EDPB opinion of October 2024] clarified that controllers must maintain a complete and documented overview of all processors and sub-processors, their roles, locations, and compliance with GDPR requirements, including rules on international data transfers. Information requests and documentation submitted by KL. Between January and June 2025, Datatilsynet repeatedly requested KL to submit documentation on behalf of the controllers, including lists of all processors and sub-processors, descriptions of their processing activities, their geographical loca
Outcome
Order
A binding order requiring the controller to take specific action.
Related Enforcement Actions (0)
No other enforcement actions found for Danish Municipalities in DK
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. Danish Municipalities - Denmark (2026). Retrieved from cookiefines.eu
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