DPA case 01/2022 (private employment agency) – Reprimand (Belgium, 2022)

On 3 January 2022 the Belgian DPA’s Litigation Chamber issued decision 01/2022, DOS-2020-01182, concerning an anonymised private employment agency. The agency failed to implement a candidate’s erasure request: despite confirming deletion on 3 March 2020, its offices sent vacancy emails that afternoon and again on 15 April 2020. The Chamber found infringements of Articles 12(2), 17(1) and 24 GDPR and issued a reprimand; paragraph 49 also addresses accountability under Article 5(2). A one-off employee error, later deletion and remedial measures mitigated the sanction but did not remove the infringement. The Chamber dismissed the separate challenges to the original vacancy-mail registration and the creation of the candidate portal account: it did not establish unlawful or insufficiently transparent processing on those grounds. No administrative fine was imposed. Judicial appeal remained possible; this source alone does not establish finality.