Enforcing jurisdiction
Iceland · Geography does not establish applicable law.
Confirmed applicable legislation

DPA case Case no. 2021101924 – Complaint Upheld (Iceland, 2022)

Complaint Upheld
Persónuvernd29 November 2022Iceland
final
Complaint Upheld

Privacy enforcement record

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Signet, a web portal for signing documents, faced a complaint for sharing users' personal data without proper consent. A user claimed her email and social security number were exposed to all users of the service. This case highlights the need for clear privacy practices when handling sensitive information online.

What happened

Signet shared a user's email address and social security number with all its users without a valid legal basis.

Who was affected

The user who complained about her personal data being shared without her consent on the Signet platform.

What the authority found

The Icelandic Data Protection Authority upheld the complaint, indicating that Signet did not have a legal basis for processing the user's personal data.

Why this matters

This case serves as a warning for online service providers to ensure they have clear consent and transparency when handling personal data, especially sensitive information.

Recorded legal citations
Automatically processed
Art. 7 GDPR
Art. 13 GDPR
Art. 14 GDPR
Art. 5(1)(a) GDPR
Art. 5(1)(b) GDPR
Art. 5(1)(c) GDPR
Art. 6(1)(a) GDPR
Art. 6(1)(f) GDPR
Art. 14(5)(b) GDPR
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Art. 6(1)(a) GDPR
Art. 6(1)(f) GDPR

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

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Automated check recorded — 18 October 2026.

Processing notes: articles corrected.

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Full Legal Summary
Detailed

Signet, the controller, is a web portal which allows its users to digitally sign and verify documents. At the time of the processing of the data subject's personal data, which is the complainant in this case, the controller used, among other things, the sharing of its users' email addresses and social security number to verify that the service connects parties securely and to ensure that documents are transferred between the correct recipients. Every user of the service gained access to this personal data. Crucially, the social security number is not stored on Signet but on the national register of Iceland. Signet, however, is an access provider to the national register. The concrete mechanisms of how the security was achieved through public access to the email addresses and social security numbers was not explained in detail, neither in the case nor on the service's website. The concerned data subject had used Signet to sign a document. For that purpose, the data subject had shared her social security number and email address with the controller. The controller published the personal data and made it available to all Signet users. Subsequently, the data subject sent a complaint to the Icelandic DPA about the processing of her data, argued that the controller had processed her personal data without a legal basis. Moreover, the data subject maintained that the processing was unlawful, unfair, not appropriate and far beyond what is necessary (see the GDPR principles in Articles 5(1)(a) and (5)(1)(b) GDPR). Additionally, the controller had not complied with its information duties pursuant to Article 13 and 14 GDPR. No information about the processing of personal data appear in the terms of use and the privacy policy was not referred to when the data subject logged into the system. The controller responded that they had processed the personal data based on the data subject's consent. When first accessing the service, the data subject had agreed to the terms of use.

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for DPA case Case no. 2021101924 in IS

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

Details

Decision Date

29 November 2022

Authority

Persónuvernd

GDPRhub ID

gdprhub-5623

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 Case no. 2021101924 - Iceland (2022). Retrieved from cookiefines.eu

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