Company – €18,700 Fine (Luxembourg, 2021)

€18,700Commission Nationale pour la Protection des Données27 October 2021Luxembourg
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Fine

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 company in Luxembourg was fined €18,700 for not properly involving its Data Protection Officer (DPO) in privacy matters. The DPO lacked direct contact details on the website and wasn't given enough authority or access to management. This case shows the importance of empowering DPOs to ensure compliance with data protection laws.

What happened

The company failed to properly involve its Data Protection Officer in data protection matters and did not provide direct contact details for the DPO.

Who was affected

The company's Data Protection Officer, who was not sufficiently involved in privacy matters.

What the authority found

The Luxembourg authority fined the company for not granting the DPO enough autonomy and access, violating GDPR requirements for DPO involvement.

Why this matters

This ruling highlights the critical role of DPOs in maintaining data protection compliance. Companies should ensure DPOs have the necessary authority and visibility to manage data privacy effectively.

Full Legal Summary
Detailed

The DPA of Luxembourg has imposed a fine of EUR 18,700 on a company. During its investigation, the DPA first found that the controller's public website did not include direct contact details for the DPO. Furthermore, the DPO was not sufficiently involved in all data protection matters. For example, they only participated in internal meetings by invitation. Moreover, there were several hierarchical intermediaries between the DPO and the highest management level of the controller, not granting them sufficient autonomy. Also, in the absence of formalized procedures, the DPO was not able to sufficiently monitor the consistency of data processing practices.

Details

Fine Date

27 October 2021

Authority

Commission Nationale pour la Protection des Données

Fine Amount

€18,700

Enforcement Tracker ID

ETid-1747

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 - Luxembourg (2021). Retrieved from cookiefines.eu

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