Íslandsbanki (Bank of Iceland) – Complaint Upheld (Iceland, 2022)

Complaint Upheld
Persónuvernd14 December 2022Iceland
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 Icelandic DPA found that the Bank of Iceland shared a person's debt information with others in their building without ensuring the data was accurate. This is important because it highlights the need for banks to verify information before sharing it. The bank must now take steps to improve data security when notifying others about debts.

What happened

The Bank of Iceland shared a person's debt status with others in their building without verifying the accuracy of the information.

Who was affected

A person who owned a property and had their debt information shared with other building residents.

What the authority found

The DPA found that the bank failed to ensure data accuracy and security, violating GDPR's requirements for data protection.

Why this matters

This case underscores the importance of verifying personal data before sharing it, especially in sensitive situations like debt notifications. Banks and similar institutions should ensure they have robust data security measures in place.

GDPR Articles Cited

Art. 6 GDPR
Art. 5(1) GDPR
Art. 5(2) GDPR
Art. 32(1) GDPR

National Law Articles

Act no. 32/2009 Article 2(2)
Act no. 32/2009 Article 7(1(d))
Full Legal Summary
Detailed

The Bank of Iceland shared the data subject’s debt status with third parties who owned flats in the same building of the data subject. According to the controller, there was an obligation to do so under national law (Article 7(1(d)) Act no. 32/2009). Essentially, in case of debts, the bank is obliged to inform the co-owner(s) of the existence and status of a mortgage on their building. The data subject filed a complaint. The DPA agreed that there was a legal obligation on the controller arising from the national provision to notify owners of the property. The processing was therefore lawful under Article 6(1) GDPR. It considered that registration books can usually be relied on for the authenticity of the information. However, in this case, the data subject had 100% ownership while the other 25 people mentioned in the registration book only had property lease agreements. The data controller therefore had every reason to examine and further investigate the registration book before sending out such notifications. Indeed, the controller was the responsible party for taking appropriate technical and organizational security measures to ensure adequate security of personal data. Consequently, the DPA held that the controller did not fulfill its duty of diligence and did not ensure appropriate security of the personal data under Article 5(2) and 32(1) GDPR. Pursuant Article 58(2)(c) GDPR, it asked the data controller to take measures to ensure the appropriate security of personal information to be maintained when sending notifications. No fine was imposed.

Outcome

Complaint Upheld

A data subject complaint that was upheld by the DPA.

Related Enforcement Actions (0)

No other enforcement actions found for Íslandsbanki (Bank of Iceland) in IS

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

Details

Decision Date

14 December 2022

Authority

Persónuvernd

GDPRhub ID

gdprhub-5687

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
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Cite as: Cookie Fines. Íslandsbanki (Bank of Iceland) - Iceland (2022). Retrieved from cookiefines.eu

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