Ministry of Education and Religious Affairs – Complaint Upheld (Greece, 2022)

Complaint Upheld
Hellenic Data Protection Authority1 November 2022Greece
final
Complaint Upheld

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.

The Hellenic Data Protection Authority found that the Ministry of Education and Religious Affairs did not fully comply with data protection rules for online learning. The ministry improved its practices by updating security measures and providing clearer information to students and parents. This matters because it shows the importance of protecting personal data in educational settings.

What happened

The Ministry of Education and Religious Affairs failed to fully comply with data protection rules for distance learning.

Who was affected

Students, parents, and teachers involved in distance learning programs were affected.

What the authority found

The authority found that the ministry did not meet GDPR requirements for data processing, transparency, and security in online education.

Why this matters

This case highlights the need for educational institutions to ensure robust data protection measures, especially when handling children's data. It emphasizes the importance of clear communication and security in digital learning environments.

GDPR Articles Cited

Art. 12 GDPR
Art. 13 GDPR
Art. 35 GDPR
Art. 46 GDPR
Art. 5(1)(a) GDPR
Art. 6(1)(e) GDPR
Art. 25(1) GDPR

National Law Articles

National Law 3471/2006, article 4
National Law 4624/19, article 37
Full Legal Summary
Detailed

The DPA examined the compliance of the Ministry of Education and Religious Affairs (the controller) with the recommendations of Decision 50/2021 on the compatibility of distant learning in the primary and secondary education sector, with the provisions of the legislation based on the processing of personal data. In the original decision, the DPA had found four different shortcomings. First, no detailed investigation had been carried out into the legality of the purposes of processing on the part of the controller, in particular in relation to consent to access information stored on a user's terminal equipment when this is not necessary for the provision of the service requested by the user. Second, the information provided to data subjects was less than that required by the GDPR, and the information was not provided in an intelligible and easily accessible form with clear and simple wording, especially if it was also addressed to children. Third, the security measures in place, although in the right direction, needed to be made accessible to every teacher, and it must be ensured that all teachers involved in the distance learning process received the minimum required information. Fourth, a proper assessment of the transfer of data to countries outside the EU had not been carried out, especially in light of the CJEU's decision in case C-311/18 (Schrems II). The DPA had issued a reprimand for each of the above discussed shortcomings. As a response to the DPA's decision, the controller adopted a number of supplementary measures in order to comply with the relevant data protection legislation. Among others, it conducted a more detailed analysis on the lawfulness of the purposes of processing. The controller also drafted a new information document regarding the processing activities, in a way that would be comprehensible for pupils, students as well as parents and staff. Moreover, new security measures were introduced next to updated supplementary measures with regards

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for Ministry of Education and Religious Affairs in GR

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

Details

Decision Date

1 November 2022

Authority

Hellenic Data Protection Authority

GDPRhub ID

gdprhub-5396

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Ministry of Education and Religious Affairs - Greece (2022). Retrieved from cookiefines.eu

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