DPA case 07121-1/2020/197 – Order (Slovenia, 2020)
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.
An advisory opinion from Slovenia's data protection authority clarified how insurance companies should handle personal data. It emphasized that insurers must collect data directly from customers and only process what is necessary under the law.
What happened
The authority provided guidance on the legal basis for insurance companies to process personal data.
Who was affected
Insurance companies and their potential policyholders in Slovenia.
What the authority found
The authority stated that insurers must follow strict legal guidelines for data collection and processing, ensuring data minimization and confidentiality.
Why this matters
This opinion serves as a reminder for businesses in the insurance sector to review their data handling practices to comply with legal requirements.
Source checks
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Automated check recorded — 18 October 2026.
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The IP received a request for an advisory opinion regarding the processing of data in the context of a life insurance policy. The IP found that pursuant to the Insurance Act the insurance companies and the Slovenian Insurance Association maintain individual databases of personal data referred to therein. Such a database could also be one of potential policyholders and insured persons in which the personal data provided for in this Act may be collected from a customer, taking into account the purpose of data processing. This personal data is therefore collected directly from the data subjects (customers). The insurer must therefore obtain the information from the customer, not itself. The processing of personal data in this database is only allowed to the extent that is necessary for the purposes of processing defined in the law. Therefore, the insurance companies have a legal basis for obtaining and processing personal data to the extent and for the purposes defined in the law. However, the IP stressed that the principle of data minimisation must be respected, so that only personal data should be processed as is strictly necessary for the exercise of legitimate powers, tasks or obligations. Specific retention periods are also provided for in the same Act, after which the personal data included in the database must be erased, destroyed or irrevocably anonymized. Further, the insurance companies have a duty to confidentiality according to the same Act. Finally, the IP concluded that it is not possible, in the context of a non-binding opinion, to determine whether, in a particular case the stated conditions for processing all the information are fulfilled. This should be done by the operator. The IP can go through a specific assessment of the legality of processing in a particular case only by an inspection or administrative procedure.
Outcome
Order
A binding order requiring the controller to take specific action.
Related Enforcement Actions (0)
No other enforcement actions found for DPA case 07121-1/2020/197 in SI
This is the only recorded action for this entity in this jurisdiction.
Details
About this data
Cite as: Cookie Fines. DPA case 07121-1/2020/197 - Slovenia (2020). Retrieved from cookiefines.eu
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