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Germany · Geography does not establish applicable law.
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Company – €525,000 Fine (Germany, 2022)

€525,000Bundesbeauftragter für den Datenschutz20 September 2022Germany
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Fine

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A German company was fined €525,000 for a conflict of interest involving its data protection officer. The officer was also managing director of two service companies that processed data for the same company. This ruling emphasizes the need for clear separation of roles in data protection.

What happened

A company was fined for having a data protection officer who had conflicting interests.

Who was affected

The subsidiary of a Berlin-based e-commerce group that failed to appoint a compliant data protection officer.

What the authority found

The DPA ruled that the company violated GDPR rules by not addressing the conflict of interest after a prior warning.

Why this matters

This case highlights the importance of having independent data protection officers. Companies should ensure that their data protection practices comply with regulations to avoid significant fines.

Recorded legal citations
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Art. 38(6) GDPR

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Full Legal Summary
Detailed

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 (0)

No other enforcement actions found for Company in DE

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

Details

Fine Date

20 September 2022

Authority

Bundesbeauftragter für den Datenschutz

Fine Amount

€525,000

Enforcement Tracker ID

ETid-1398

About this data

Data: CMS GDPR Enforcement Tracker
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Company - Germany (2022). Retrieved from cookiefines.eu

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