- Enforcing jurisdiction
- Iceland · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
Chief Epidemiologist of the Office of the Medical Director of Health – Violation Found (Iceland, 2021)
Privacy enforcement record
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The Icelandic Data Protection Authority investigated the Chief Epidemiologist for outsourcing COVID-19 testing and found some issues with their agreements. They noted that while the testing was mostly compliant, the agreements lacked important details. This matters because it shows that even government agencies must follow data protection rules carefully.
What happened
The DPA found that the Chief Epidemiologist's data processing agreements were incomplete.
Who was affected
Individuals whose personal data was processed during COVID-19 screening and testing.
What the authority found
The DPA ruled that the Chief Epidemiologist needed to update their data processing agreements to meet legal requirements.
Why this matters
This ruling highlights that all organizations, including public health entities, must ensure their data agreements are thorough and compliant. It serves as a reminder for others to review their own data handling practices.
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Entities Involved
Source checks
Linked-source text retrieved.
Automated check recorded — 23 March 2026.
Processing notes: national law identified.
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Upon learning that the Chief Epidemiologist had outsourced screening for the SARS-CoV-2 virus as well as antibody testing to a hospital and a genetic research company, the Icelandic DPA initiated an investigation into the lawfulness of the processing. The Icelandic DPA first highlighted that, in connection with the virus screening and antibody testing, the Chief Epidemiologist acted as a controller in accordance with the Icelandic Epidemiology Act. The Icelandic DPA further found that Landspítali (the Hospital) was only processing personal data on behalf of the Chief Epidemiologist, and was thus acting as a processor, while the company Icelandic Genetics (Icelandic Genetics) was acting as a sub-processor of the personal data. The Icelandic DPA held that the processing of personal data for SARS-CoV-2 screening and testing by the the Chief Epidemiologist and the Hospital was overall compliant with data protection law. However, the Icelandic DPA found that the data processing agreement between the Chief Epidemiologist and the Hospital was incomplete with regards to several requirements set in Article 28(3) GDPR, and notably points b, c, e, f, g and h. For example, the processing agreement did not contain any information on the deletion or return of personal data (Article 28(3)(g) GDPR). In addition, the processing agreement was referencing outdated data protection legislation. The DPA therefore ordered the Chief Epidemiologist to enter into a new data processing agreement with the Hospital which would comply with all the requirements of Article 28(3) GDPR. Furthermore, the Icelandic DPA held that the data subjects should have received more information on the purpose of the processing by Icelandic Genetics pursuant to Article 14(1) GDPR. In particular, it was unclear whether the screening and testing only served as a measure for disease control or whether it could also be used for scientific research. The Icelandic DPA therefore concluded that Icelandic Genetics sho
Outcome
Violation Found
The DPA found a violation but did not impose a fine.
Related Enforcement Actions (0)
No other enforcement actions found for Chief Epidemiologist of the Office of the Medical Director of Health in IS
This is the only recorded action for this entity in this jurisdiction.
Details
Decision Date
23 November 2021
Authority
Persónuvernd
About this data
Cite as: Cookie Fines. Chief Epidemiologist of the Office of the Medical Director of Health - Iceland (2021). Retrieved from cookiefines.eu
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