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Silkeborg Municipality – Complaint Upheld (Denmark, 2021)

Complaint Upheld
Datatilsynet (Denmark)25 November 2021Denmark
final
Complaint Upheld

Privacy enforcement record

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Silkeborg Municipality in Denmark mistakenly sent sensitive information about over 12,000 children to a consulting agency without proper encryption. This incident highlights the importance of securing personal data, especially when it involves children, to prevent unauthorized access.

What happened

Silkeborg Municipality sent unencrypted information about 12,916 children to a consulting agency.

Who was affected

Children in public schools whose personal information was included in the unencrypted email.

What the authority found

The Danish DPA found that the municipality did not implement adequate security measures to protect sensitive personal data as required by GDPR.

Why this matters

This case emphasizes the need for organizations to use strong security measures, like end-to-end encryption, to protect sensitive information. It serves as a reminder for all businesses to review their data protection practices.

Recorded legal citations
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Art. 32(1) GDPR
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Art. 32(1) GDPR

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Full Legal Summary
Detailed

Due to a human error, a Danish municipality had sent a list of information regarding 12 916 children in public school to a consulting agency without properly encrypting the content. The information included the children's national identity numbers, school names and school codes. When the error was discovered, the municipality notified the Danish DPA of the incident. The municipality reported that the content of the email had possibly been encrypted on the transportation layer using TLS 1.1, however end-to-end encryption had not been implemented. The Danish DPA did not have enough evidence to conclude that TLS 1.1 had been used on the transportation layer when this specific email was sent. Moreover, the DPA held that encryption on the transportation layer is insufficient if the email contains personal data of a sensitive nature or personal data that deserve a high level of protection. In such instances, end-to-end encryption is a more adequate security measure. Furthermore, the DPA highlighted the fact that TLS 1.1 suffers from well known security issues, and that the protocol is therefore not suitable for encryption on the transportation layer. The DPA therefore concluded that the controller had not fulfilled its obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk under Article 32(1) GDPR.

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for Silkeborg Municipality in DK

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

Details

Decision Date

25 November 2021

Authority

Datatilsynet (Denmark)

About this data

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

Cite as: Cookie Fines. Silkeborg Municipality - Denmark (2021). Retrieved from cookiefines.eu

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