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DPA case 11.17.001.008.147 – Complaint Upheld (Cyprus, 2023)

Complaint Upheld
DPA Commissioner5 December 2023Cyprus
final
Complaint Upheld

Privacy enforcement record

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A Cypriot data protection authority found that an education service did not properly handle a request for personal data access. This matters because it shows that organizations must follow the rules when people ask to see their data.

What happened

The education service failed to fully comply with a request for access to personal data.

Who was affected

Candidates who requested access to their examination results and related documents.

What the authority found

The authority ruled that the service did not take appropriate action on the access request, breaching data protection rules.

Why this matters

This ruling emphasizes the importance of timely and complete responses to data access requests. Organizations should ensure they have clear processes for handling such requests.

Recorded legal citations
Automatically processed
Art. 28(3) GDPR
Art. 36(4) GDPR
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Art. 4(GDPR)
Art. 28(GDPR)
Art. 36(4) GDPR

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

National Law Articles
AI-identified
Art. 13(1) Law 125(I)/2018

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Secondary-source text retrieved.

Automated check recorded — 18 October 2026.

Processing notes: articles corrected, national law identified.

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

The Examinations Service of the Directorate of Higher Education of the Ministry of Education, Sports and Youth is the controller for the processing of personal data which is carried out in the context of the statistical processing of the results of the Examinations.In order to be registered in the list of appointments, it is necessary to record the qualifications of the candidates themselves and to submit certificates / proofs, so that they receive a relevant score. In order for a candidate to be included in the appointment list, success in the Examinations is required. In each specialty, a list of appointments is created, which includes successful Exams of various years. In specified periods, the appointment table of each specialty is renewed, by adding the successful candidates of the new Examinations and/or by differentiating the scoring of the qualifications and/or the score of each successful candidate. Comparability of Exam scores from different years is therefore required. Therefore, statistical processing is applied for the purposes of uniform ranking of candidates. The application of statistical processing methods aims to create an index that reflects the degree of difficulty of the 2019 Exam in relation to the degree of difficulty of the corresponding Exam of 2017. These methods include methods that require the processing of personal data. Apart from the existence of a relevant legal basis, since the statistical processing is provided for in the relevant Regulations, the DPA judged that the application of such methods does not come out, but instead is part of actions to achieve the intended purpose, namely the ranking of candidates in the appointment tables. The DPA held that the Service assigned the application of the statistical processing to processors, without the execution of a relevant contract of assignment, as provided for in article 28(3) of the GDPR.Furthermore , the Service did not conduct a prior consultation with the DPA for Registration a

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 11.17.001.008.147 in CY

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

Details

Decision Date

5 December 2023

Authority

DPA Commissioner

GDPRhub ID

gdprhub-7646

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. DPA case 11.17.001.008.147 - Cyprus (2023). Retrieved from cookiefines.eu

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