DEI S.A. – €880,000 Fine (Greece, 2026)

The Greek DPA (HDPA) received twelve complaints filed against DEI, the Greek Public Power Corporation, (the controller) from telephone subscribers (data subjects) regarding the receipt of telephone calls for the purpose of promoting its products and services. The controller had outsourced the telephone calls to four call-centre companies acting as processors: CQS S.A. (Processor A), Teleperformance (Processor B), Mediatel (Processor C) and Prelude Group (Processor D). Processor D stated that it had used the services of INFOBELL (subcontractor) for the operation of its outbound calling system. The controller stated that its processors made approximately two million calls per year to provide contract-related information and conduct customer-satisfaction surveys, as well as around 50,000 promotional calls per month. The complaints concerned calls made on the controller’s behalf relating to billing and tariff information, the expiry of electricity supply contracts, customer-satisfaction surveys and other products or services. One complaint concerned an Air Miles programme, through which customers could collect airline miles. Several data subjects had either registered their telephone numbers in the national opt-out register or had expressly asked not to be contacted again. Under Article 11 of Greek Law 3471/2006, telephone subscribers may register their numbers in a national do not call register to indicate that they do not wish to receive unsolicited marketing calls. In two cases, the controller acknowledged that calls had been made to numbers included in the Greek Do Not Call register and attributed this to a technical malfunction in the process used to compare and exclude telephone numbers from the calling lists. In another case, a request not to receive further calls was processed eleven days after it was first submitted. The case file also concerned calls described by the controller and the processors as informational or as surveys regarding customer-satisfaction