- Enforcing jurisdiction
- Iceland · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
Borgarholtsskóli – Violation Found (Iceland, 2026)
Privacy enforcement record
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Borgarholtsskóli, a school, was found to have improperly processed personal data from anonymous tips submitted through its website. The data protection authority ruled that the school did not follow the rules for handling such data. This case serves as a reminder for organizations to ensure transparency and legality in their data collection practices.
What happened
The DPA found that Borgarholtsskóli violated GDPR by processing anonymous tips that included personal data without proper legal justification.
Who was affected
A teacher who complained that their personal data was processed unlawfully through anonymous feedback on the school's website.
What the authority found
The DPA determined that the school did not provide sufficient evidence to justify the processing of anonymous tips under GDPR.
Why this matters
This case highlights the need for schools and organizations to clearly define the purpose of data collection and ensure compliance with data protection laws.
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Automated check recorded — 5 September 2026.
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The DPA received a complaint from a data subject regarding the processing of their personal data by Borgarholtsskóli (a school and the controller) in connection with an anonymous tip received via the feedback button on the controller’s website. The tip received regarded the data subject and their teaching methods, which according to the data subject were fabrications, misrepresentations and slander. In their complaint, the data subject claimed that their personal data was not processed in a lawful, fair and transparent manner, and demanded that the false and anonymous defamation about them be deleted from the controller’s system. Particularly, as the purpose and objective of the feedback button was not clearly stated. In its defence the controller clarified that where an individual submits a general tip, voluntarily providing their personal data, the processing of such is based on consent. On the other hand, when an anonymous tip, which contains personal data about a third party, the processing operations are based on compliance with a legal obligation particularly in improving the quality of education. Supporting its statement with national law, the controller stated that the feedback button is necessary for the controller’s operations, ensuring they are able to fulfill their national law obligations. Ultimately, the dispute concerned whether the controller was authorised to accept the anonymous tip and subsequently save it in its system, as well as whether the controller should delete the anonymous tip from its system. The DPA found the data processing of the controller in violation of Article 5(1)(a)-(d) GDPR and Article 6(1) GDPR. Particularly, the DPA found that whilst the controller had obligations under national education laws, this did not automatically extend to the acceptance and processing of anonymous complaints. The DPA therefore held that the controller did not provide sufficient evidence to justify that its processing was necessary to comply with a legal obligation pursuant to Article 6(1)(c). Furthermore, the DPA clarified that the data subject’s right to erasure does not apply if retention is necessary for archiving purposes in the public interest in light of national archive laws. The DPA issued a reprimand against the controller ordering it to review the collection of personal data through their feedback form on the website, and ensure that they bring their data processing obligations into compliance with Articles 5(1)(a)-(d) GDPR and Article 6(1) GDPR.
Outcome
Violation Found
The DPA found a violation but did not impose a fine.
Related Enforcement Actions (0)
No other enforcement actions found for Borgarholtsskóli in IS
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. Borgarholtsskóli - Iceland (2026). Retrieved from cookiefines.eu
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