Company – €525,000 Fine (Germany, 2022)
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.
A Berlin-based e-commerce group was fined EUR 525,000 for a conflict of interest involving their data protection officer. The officer was also a managing director of companies processing data for the group. This case highlights the importance of avoiding conflicts of interest in data protection roles.
What happened
A Berlin e-commerce company was fined EUR 525,000 for having a data protection officer who also managed data-processing companies within the same group.
Who was affected
The fine affected the e-commerce company and its data protection officer, impacting how the company manages data protection roles.
What the authority found
The Berlin DPA found a conflict of interest, violating GDPR Article 38(6), as the data protection officer held conflicting roles.
Why this matters
This fine underscores the need for companies to ensure their data protection officers are free from conflicts of interest. It serves as a reminder for businesses to carefully structure their data protection roles to comply with GDPR.
GDPR Articles Cited
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The DPA of Berlin has imposed a fine of EUR 525,000 on the subsidiary of a Berlin-based e-commerce group. The company had appointed a data protection officer, who however was also the managing director of two service companies that processed personal data on behalf of the very same company for which they acted as data protection officer. These service companies are also part of the group to which the e-commerce company belongs. The DPA considered this to be a conflict of interest and found a violation of Art. 38 (6) GDPR. The DPA had already issued a warning to the company in 2021 due to the conflict of interest. When a new inspection this year revealed that no new data protection officer had been appointed, the DPA imposed the fine.
Related Enforcement Actions (20)
Other enforcement actions involving Company in DE
Fine
€525K
Details
Fine Date
20 September 2022
Authority
Bundesbeauftragter für den Datenschutz
Fine Amount
€525,000
Enforcement Tracker ID
ETid-1398
About this data
Cite as: Cookie Fines. Company - Germany (2022). Retrieved from cookiefines.eu
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