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City of Reykjavík – €36,000 Fine (Iceland, 2022)

€36,000Persónuvernd3 May 2022Iceland
final
Fine

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The City of Reykjavík was fined EUR 36,000 for mishandling personal data of students using the Seesaw education system. The Icelandic data protection authority found that the city did not clearly define how it was using the children's data and failed to protect it properly. This case highlights the importance of having clear data protection measures in place, especially when dealing with minors' information.

What happened

The City of Reykjavík used the Seesaw digital education system without properly defining the purpose of processing students' personal data.

Who was affected

Minor students whose personal data, including teacher feedback and private information, was processed by the Seesaw system.

What the authority found

The authority ruled that Reykjavík did not implement adequate measures to protect personal data, violating GDPR's principles of purpose limitation and data minimization.

Why this matters

This ruling emphasizes that organizations must have clear data protection strategies, especially when handling sensitive information about children. Other schools and educational institutions should review their data practices to ensure compliance.

Recorded legal citations
Automatically processed
Art. 5 GDPR
Art. 6 GDPR
Art. 32 GDPR
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Art. 5(GDPR)
Art. 6(GDPR)
Art. 32(GDPR)

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Linked-source text retrieved.

Automated check recorded — 12 March 2026.

Processing notes: articles corrected, national law identified.

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Full Legal Summary
Detailed

The Icelandic DPA has imposed a fine of EUR 36,000 on the City of Reykjavík. The city had used the digital education system 'Seesaw' at several schools. The student system processed, among other things, personal data of minor students such as teacher feedback and information about students' private affairs. During its investigation, the DPA found that the purpose of the processing of the children's data had not been sufficiently clearly defined. In this context, the DPA also found a breach of the principle of proportionality and data minimization. In addition, the DPA concluded that the city had not implemented adequate technical and organizational measures regarding the protection of personal data. This would have been necessary given the high risk that the data might be transferred to and processed in the United States. In determining the fine, mitigating consideration was given to the fact that no damage was caused by the data breaches.

Related Enforcement Actions (0)

No other enforcement actions found for City of Reykjavík in IS

This is the only recorded action for this entity in this jurisdiction.

Details

Fine Date

3 May 2022

Authority

Persónuvernd

Fine Amount

€36,000

About this data

Data: CMS GDPR Enforcement Tracker
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. City of Reykjavík - Iceland (2022). Retrieved from cookiefines.eu

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