Zagreb Holding d.o.o. – €25,000 Fine (Croatia, 2023)

€25,000Agencija za zaštitu osobnih podataka13 September 2023Croatia
final
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.

Zagreb Holding d.o.o. was fined EUR 25,000 for asking users to send copies of their personal identification cards before sending invoices via email. The company didn't have clear rules for identifying users and failed to inform them about why they needed this personal data. This case highlights the importance of having proper identification processes and transparency when handling personal information.

What happened

Zagreb Holding requested personal identification card copies from users before issuing invoices via email.

Who was affected

Users who requested invoices via email and had to provide personal identification documents.

What the authority found

The DPA found that Zagreb Holding lacked proper identification measures and failed to inform users about the legal basis for collecting their personal data.

Why this matters

This ruling emphasizes that companies must have clear procedures for identifying users and must be transparent about data collection. Other businesses should review their identification processes to avoid similar issues.

GDPR Articles Cited

Art. 13(1)(c) GDPR
Art. 13(2)(a) GDPR
Art. 25(2) GDPR
Full Legal Summary
Detailed

The Croatian DPA (AZOP) has imposed a fine of EUR 25,000 on Zagreb Holding d.o.o., utilities company owned by the city of Zagreb. The DPA had received a complaint from a citizen concerning Zagreb Holding's practice of requesting a copy of users' personal identification cards before issuing invoices via email. Previously, to receive invoice by email the users only needed to provide their name, surname, address, personal identification number, facility number and their user number. During the investigation, it was found that Zagreb Holding lacked established rules for identifying service users requesting invoice copies via email and only collected copies of identification documents when there was suspicion of false representation. The company requested personal identification document copies from users whose email addresses had a different name/ structure than their name and surname, or if the user's name and surname in the email address did not match the requested invoice copy email address's structure. The DPA found that the mere inclusion of the correct name and surname in an email address is an insufficient protective measure. Consequently, the data controller failed to implement appropriate technical and organizational measures for user identification, contrary to Art. 25 (2) GDPR. According to the explanation given by the DPA, the data controller should have developed a process for identification via email ensuring a uniform procedure for all users, regardless of the email address structure. Furthermore, the data controller failed to transparently inform service users about the legal basis for collecting personal data (scan of personal identification card) for identification purposes. Such information were not available on the company's official website nor provided upon direct request via email.

Related Enforcement Actions (0)

No other enforcement actions found for Zagreb Holding d.o.o. in HR

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

Details

Fine Date

13 September 2023

Authority

Agencija za zaštitu osobnih podataka

Fine Amount

€25,000

Enforcement Tracker ID

ETid-2059

About this data

Data: CMS GDPR Enforcement Tracker
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Cite as: Cookie Fines. Zagreb Holding d.o.o. - Croatia (2023). Retrieved from cookiefines.eu

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