DPA case nr. 2020123070 – Dismissed (Iceland, 2021)

Dismissed
Persónuvernd26 November 2021Iceland
final
Dismissed

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 employee complained that his company did not give him a written copy of a reprimand he received. The data protection authority dismissed the complaint, stating it was a labor issue rather than a data protection one. This case shows that not all workplace disputes fall under data protection laws.

What happened

The data protection authority dismissed a complaint about a company not providing a written reprimand to an employee.

Who was affected

The employee who requested a written copy of his reprimand from the company.

What the authority found

The authority found that the issue was related to labor law, not data protection law, and therefore could not assess the complaint.

Why this matters

This case highlights the distinction between labor law and data protection issues. It reminds businesses to understand the boundaries of data protection regulations.

GDPR Articles Cited
Automatically processed
Art. 15 GDPR
Art. 5(1)(a) GDPR
View original scraped data
Art. 15(GDPR)

Original imported citations before automated processing; the processing history does not establish independent verification.

Source checks

Secondary-source text retrieved.

Automated check recorded — 18 October 2026.

Processing notes: articles corrected.

Retrieved text may be a secondary summary or an announcement. These automated statuses do not establish that the original decision was read or that the record received an independent legal review. How we check sources

Full Legal Summary
Detailed

In 2017, an employee (the Complainant) had been subject to a formal reprimand by his employer (the Company), but had allegedly not been informed about it. Two years later, after being subject to a second reprimand, the Complainant learned about the first formal reprimand against him, and orally requested the Company to provide him with a written copy of it. The Company, however, did not provide him with a written copy of the first reprimand. In that context, the Complainant filed a complaint with the Icelandic DPA against the Company, arguing that the Company had never provided him with a copy of the first formal reprimand against him, despite his (alleged) oral request. The Complainant considered in particular that the Company had acted in violation of the principle of transparency and fairness set in Article 5(1)(a) GDPR, and of his right to access set in Article 15 GDPR. In the course of the proceedings, the Company argued that the Complainant had never personally requested a copy of the reprimand, but that his union had done so in January 2021. The Company further explained to the Icelandic DPA that it had complied with that request on the same day, providing as evidence a copy of the e-mail communication between the Company and the union. Regarding the potential violation of Article 5(1)(a) GDPR, the Icelandic DPA considered that the question whether the Company should have more diligently informed the Complainant about the first reprimand was a matter of labour law rather than a matter of data protection law. Hence, the Icelandic DPA declared itself incompetent to assess whether the (absence of) communication of the first reprimand to the Complainant was violating the principle of transparency and fairness. Regarding the potential violation of Article 15 GDPR, the Icelandic DPA noted that the Company was disputing the fact that the Complainant had ever submitted an oral request for receiving a written copy of the first reprimand. The Complainant, for his par

Outcome

Dismissed

The complaint or investigation was dismissed.

Related Enforcement Actions (0)

No other enforcement actions found for DPA case nr. 2020123070 in IS

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

Details

Decision Date

26 November 2021

Authority

Persónuvernd

GDPRhub ID

gdprhub-4387

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. DPA case nr. 2020123070 - Iceland (2021). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: