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

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

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A company in Luxembourg was fined €18,700 for not providing clear contact details for its Data Protection Officer (DPO) on its website. The DPO also wasn't involved enough in important data protection matters. This matters because it shows that companies must ensure their DPOs are accessible and actively involved in data protection.

What happened

The Luxembourg DPA fined a company for failing to include direct contact details for its DPO and not involving the DPO sufficiently in data protection matters.

Who was affected

Visitors to the company's website who expected to find contact information for the DPO were affected.

What the authority found

The DPA found that the company did not meet the requirements for DPO accessibility and involvement, violating GDPR rules.

Why this matters

This case highlights the importance of having a well-integrated DPO in data protection practices. Companies should ensure their DPOs are easily reachable and involved in key decisions.

Recorded legal citations
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Art. 37(7) GDPR
Art. 38(1) GDPR
(3) GDPR
Art. 39(1) b) GDPR

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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

GDPRhub ID

gdprhub-4380

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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