- Enforcing jurisdiction
- Denmark · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
TV 2 – Complaint Upheld (Denmark, 2022)
Privacy enforcement record
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Denmark's data protection authority upheld a complaint against TV 2 for mishandling sensitive personal data during an investigation into workplace culture. The authority found that the TV station and its law firm partners did not have a valid legal basis for processing the complainant's sensitive data. This ruling emphasizes the importance of proper legal grounds when handling personal information.
What happened
The authority found that TV 2 and its law firm processed sensitive personal data without a valid legal basis.
Who was affected
A past employee of TV 2, who was investigated for alleged misconduct, was affected by this decision.
What the authority found
The authority ruled that TV 2 could not rely on legal obligations to justify processing the sensitive data, violating GDPR requirements.
Why this matters
This ruling serves as a reminder for companies to ensure they have a clear legal basis when processing sensitive personal data. It reinforces the need for transparency and compliance in workplace investigations.
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Entities Involved
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Controllers are TV 2 Danmark A/S (a public TV station) and Norrbom Vinding I/S (a law firm). In September 2020, TV 2 launched an investigation into the unhealthy (sexist) culture at the TV station. It asked the help of law firm Norrbom Vinding, and asked past- and present employees to report infringements and share their experiences with the sexist culture at TV 2. The TV station then received two reports on the data subject, with allegations regarding sexual misconduct. After investigating the matter, TV 2 decided that data subject could no longer host any TV shows on the station. Data subject argued that there were no concrete facts that justified the investigation of TV 2. Moreover, they found that, since they did not explicitly consent to any processing, TV 2 and Norrbom Vinding processed their sensitive personal data without a legal basis. Hence, they filed a complaint with the DPA. First, the DPA assessed the general legal basis. It found that TV 2 and Norrbom Vinding could not rely on Article 6(1)(c) GDPR, when processing data subject’s personal data, since the legal obligations laid down in the health and safety and discrimination law are not sufficiently clear and precise to be used as a basis for processing within the scope of Article 6(1)(c). However, the DPA stated that the controller could rely on Article 6(1)(f) GDPR, because the objective of the investigation “ending unhealthy culture” was legitimate, and this objective overrode the interests of data subject. Secondly, the DPA noted that the controllers could not rely on the exception laid down in Article 9(2)(b) GDPR. Again, because the legal obligations laid down in the health and safety and discrimination law are not sufficiently clear and precise. Moreover, although the purpose of the processing was legitimate, the DPA found that the controllers could also not rely on Article 9(1)(f) GDPR. The DPA considered that, because the collection of sensitive personal data was not restricted sufficient
Outcome
Complaint Upheld
A data subject complaint that was upheld by the DPA.
Related Enforcement Actions (0)
No other enforcement actions found for TV 2 in DK
This is the only recorded action for this entity in this jurisdiction.
Details
Decision Date
3 February 2022
Authority
Datatilsynet (Denmark)
About this data
Cite as: Cookie Fines. TV 2 - Denmark (2022). Retrieved from cookiefines.eu
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