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Croatia · Geography does not establish applicable law.
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Telecommunications operator (operator of electronic communications networks and services) – €4,500,000 Fine (Croatia, 2025)

€4,500,000Agencija za zaštitu osobnih podataka24 November 2025Croatia
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Privacy enforcement record

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A telecommunications operator was fined EUR 4.5 million for multiple violations of GDPR, including improperly transferring customer data to a processor in Serbia without adequate protections. This case is significant because it shows the serious consequences of failing to protect customer data during international transfers.

What happened

The telecommunications operator transferred customer personal data to a processor in Serbia without proper safeguards.

Who was affected

847,862 customers whose personal data was transferred to a Serbian processor without adequate protections.

What the authority found

The data authority found that the operator violated GDPR by transferring data without necessary safeguards and failing to inform customers about these transfers.

Why this matters

This ruling serves as a warning to companies about the importance of complying with data transfer regulations. Businesses must ensure they have the right protections in place when handling customer data internationally.

Recorded legal citations
Automatically processed
Art. 44 GDPR
Art. 5(1)(b) GDPR
Art. 6(1) GDPR
Art. 12(1) GDPR
Art. 13(1)(f) GDPR
Art. 28(1) GDPR
Art. 46(1) GDPR
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Art. 5(1)(b) GDPR
c)
(2) GDPR
Art. 6(1) GDPR
Art. 12(1) GDPR
Art. 13(1)(f) GDPR
Art. 28(1) GDPR
Art. 44 GDPR
Art. 46(1) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

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Full Legal Summary
Detailed

Following an ex officio investigation, AZOP imposed a EUR 4.5 million fine on a telecommunications operator for multiple GDPR infringements. The controller transferred customer personal data to a processor in the Republic of Serbia (a group company maintaining software). Transfers had been based on Standard Contractual Clauses (SCCs) from 16 April 2020 until at the latest 27 December 2022; after that date, transfers continued without SCCs or equivalent safeguards, despite Serbia lacking an adequacy decision. The Serbian processor had administrator access to the controller’s SAP CRM database covering 847,862 data subjects, with access to extensive customer data (including name, Personal Identification Number, address, service/installation/billing addresses, contact details, email, IBAN for SEPA direct debit users, MSISDN, ICCID, and service information). The controller also failed to conduct a transfer risk assessment before commencing transfers. In addition, the controller did not transparently inform data subjects about third-country transfers, using vague “may” language in privacy policies instead of clearly stating that data are transferred outside the EEA, thereby breaching transparency obligations. Separately, the controller excessively processed employee data by collecting copies of employees’ ID cards and certificates of no criminal proceedings without a valid legal basis and contrary to the data minimisation and purpose limitation principles; notably, it disregarded its DPO’s opinion flagging such collection as excessive. Finally, the controller failed to carry out prior checks of a telesales processor’s security measures and engaged a processor lacking even basic safeguards, in breach of Article 28(1) GDPR.

Related Enforcement Actions (0)

No other enforcement actions found for Telecommunications operator (operator of electronic communications networks and services) in HR

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

Details

Fine Date

24 November 2025

Authority

Agencija za zaštitu osobnih podataka

Fine Amount

€4,500,000

Enforcement Tracker ID

ETid-2937

About this data

Data: CMS GDPR Enforcement Tracker
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. Telecommunications operator (operator of electronic communications networks and services) - Croatia (2025). Retrieved from cookiefines.eu

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