Enforcing jurisdiction
Croatia · Geography does not establish applicable law.
Confirmed applicable legislation

Centre for Social Welfare – Complaint Upheld (Croatia, 2022)

Complaint Upheld
Agencija za zaštitu osobnih podataka29 June 2022Croatia
final
Complaint Upheld

Privacy enforcement record

This record is classified outside cookie consent. Subject classification does not confirm an applicable law. It is not included in cookie statistics or the Risk Calculator.

The Centre for Social Welfare published personal information about its employees on a bulletin board without a valid reason. The Croatian data protection authority found this was not allowed under data protection rules. This case highlights the importance of having a legal basis before sharing personal information publicly.

What happened

The Centre for Social Welfare published employees' names and holiday information on a bulletin board without a valid legal basis.

Who was affected

Employees of the Centre for Social Welfare whose personal data was published on the bulletin board.

What the authority found

The authority ruled that the Centre for Social Welfare did not prove a valid legal basis for publishing personal data, violating Articles 5 and 6 of GDPR.

Why this matters

This decision emphasizes that organizations must ensure they have a legal reason to share personal data. It serves as a reminder for companies to carefully evaluate their data-sharing practices.

Recorded legal citations
Automatically processed
Art. 5 GDPR
Art. 6 GDPR
View original scraped data
Art. 5(GDPR)
Art. 6(GDPR)

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

National Law Articles
AI-identified
Article 29 Croatian Labour Act

Source checks

Linked-source text retrieved.

Automated check recorded — 18 March 2026.

Processing notes: national law identified.

Retrieved text may be a secondary summary or an announcement. These automated statuses do not establish that the original decision was read or that the record received an independent legal review. How we check sources

Full Legal Summary
Detailed

In March 2022, the Center for Social Welfare (the controller) published a decision on using remaining annual leave for 2021 on its bulletin board. It included the first and last names and the number of used and remaining holidays of the data subject and other of the controller's employees. The data subject doubted the lawfulness of the publication and therefore filed a complaint at the Croatian DPA. The DPA held that the controller did not prove the existence of a valid legal basis for the publication of employees' personal data on the bulletin board. First, arguing around the possible controller's legitimate interests, the DPA pointed out that the controller failed to carry out a proportionality test which should consider a number of factors to ensure that the interests and fundamental rights of data subjects are taken into account. Second, the DPA held that the controller was not under a legal obligation to process these data. Article 29 of the Croatian Labour Act and Article 5(4) of the Labour Law Rulebook (Official Gazette, no. 73/17) refer, among others, to maintaining records of employees' working time as part of the employer's legal obligation. However, the DPA empshasised that Croatian labour law does not, in fact, prescribe the publication of this data. Consequently, the DPA held that the controller violated Articles 5 and 6 GDPR. In addition, it ordered the controller to stop further processing of any personal data of the data subject or other employees on its bulletin board without a valid legal basis.

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for Centre for Social Welfare in HR

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

Details

Decision Date

29 June 2022

Authority

Agencija za zaštitu osobnih podataka

GDPRhub ID

gdprhub-5257

About this data

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

Cite as: Cookie Fines. Centre for Social Welfare - Croatia (2022). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: