Kombit A/S โ€“ Violation Found (Denmark, 2020)

Violation Found
Datatilsynet (Norway)22 September 2020Denmark
final
Violation Found

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.

Kombit A/S, managing a municipal information system in Denmark, failed to restrict access to sensitive data, allowing unauthorized access for four months. This incident exposed the social security numbers and employment details of 4.2 million Danish citizens. The Danish Data Protection Agency found Kombit A/S violated GDPR by not implementing proper security measures.

What happened

Kombit A/S allowed unauthorized access to sensitive data of 4.2 million citizens by failing to limit access in a municipal information system.

Who was affected

Danish citizens whose social security numbers and employment details were accessed by unauthorized parties.

What the authority found

The Danish Data Protection Agency ruled that Kombit A/S failed to implement necessary security measures, violating GDPR requirements for data processors.

Why this matters

This case highlights the importance of ensuring strict access controls in data management systems. Companies managing sensitive data must regularly test and verify their systems to prevent unauthorized access.

GDPR Articles Cited

Art. 32 GDPR
Art. 28(1) GDPR
Full Legal Summary
Detailed

In December 2018 - February 2019, the Danish Data Protection Agency received a number of notifications from the country's municipalities regarding the Joint Municipal Management Information System (FLIS). The purpose of the system was to provide management information to the municipalities. However, the company managing the FLIS system (Kombit A/S), which in this instance was acting as processor, mistakenly forgot to limit the access to the data of the individual municipalities. Therefore, for the duration of 4 months, individual municipalities and suppliers of Business intelligence could illegally access the social security numbers and employment details of 4.2 million Danish citizens. Whether the processor of the data (Kombit A/S) had acted wrongfully by allowing this technical error to go on for four months. The processor of the information management system (Kombit A/S) tried to argue that no data was made publicly available on the Internet. However, it follows from Article 28(1) GDPR and Article 28(3)(f) GDPR that the data processor (in this instance Kombit A/S) is required to assist the data controller (the Danish municipalities) in ensuring compliance with the obligations under Articles 32 to 36, taking into account the nature of the processing and the information available to the data processor. The DPA also held that it followed from Article 32(1) GDPR that the data controller and the data processor must implement appropriate technical and organizational measures to ensure the continued confidentiality of processing systems and services. In context, the DPA held that this meant that both the controller and processor had to ensure that the system which had been implemented (FLIS) had been tested for inconveniences. As a result of an error in the setup of a particular data filter in FLIS, there had been an unlawful disclosure of information, which involved information relating to the social security numbers and employment of 4.2 million Danish citizens.

Outcome

Violation Found

The DPA found a violation but did not impose a fine.

Related Enforcement Actions (0)

No other enforcement actions found for Kombit A/S in DK

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

Details

Decision Date

22 September 2020

Authority

Datatilsynet (Norway)

GDPRhub ID

gdprhub-2770

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
AI-verified and classified

Cite as: Cookie Fines. Kombit A/S - Denmark (2020). Retrieved from cookiefines.eu

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