DPA case 05/01/2026 – €6,636 Fine (Croatia, 2026)

On 20 August 2025, the Croatian Data Protection Authority (AZOP) carried out an unannounced inspection in a context of an ex oficio investigation at a retail branch inside a shopping centre (the controller). The inspection examined the processing of personal data through a video surveillance system installed in the shop. During the inspection, AZOP found seven surveillance cameras installed inside the store. A store employee informed the authority that the system had been installed when the branch opened in 2016. The controller used the cameras to protect employees, property and goods in the shop. Employees could access the recordings through a computer using an application. The authority checked the system and confirmed that recordings were stored and that the oldest available recording dated from 18 August 2025. AZOP inspected the premises and found that the controller had not displayed any notice informing visitors that the space was under video surveillance. The authority did not find a sign at the entrance of the shop, on the storefront window or inside the premises. AZOP held that the controller violated Article 27(1) of the Croatian Act on the Implementation of the General Data Protection Regulation (Zakon o provedbi Opće uredbe o zaštiti podataka). Article 27(1) of the Act requires controllers to mark the premises and surrounding areas under video surveillance. AZOP clarified that this obligation ensures transparency when controllers process personal data through video surveillance. Video recordings that show identifiable individuals constitute personal data processing. Therefore, individuals must be informed about the monitoring before they enter the recorded area. The authority further explained that Article 27(2) of the Act requires the information provided under Article 27(1) to comply with the information requirements of Article 13 GDPR. When determining the sanction under Article 83(2) GDPR, AZOP considered the duration and seriousness of the infring