- Enforcing jurisdiction
- Iceland · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
Íslandsbanki (Bank of Iceland) – Complaint Upheld (Iceland, 2022)
Privacy enforcement record
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The Bank of Iceland was found to have shared a customer's debt status with third parties, but the Data Protection Authority ruled that this was lawful under national law. However, the bank was criticized for not ensuring proper security measures when sharing this information. This case highlights the need for organizations to protect personal data even when sharing it is legally required.
What happened
The bank shared a customer's debt information with property co-owners as required by national law.
Who was affected
The customer whose debt status was shared with other property owners.
What the authority found
The DPA confirmed that the bank's data processing was lawful but noted deficiencies in security measures.
Why this matters
This case illustrates the balance between legal obligations and the need for data security. Organizations must ensure they protect personal data adequately, even when sharing it is necessary.
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Linked-source text retrieved.
Automated check recorded — 23 March 2026.
Processing notes: articles corrected, national law identified.
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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
About this data
Cite as: Cookie Fines. Íslandsbanki (Bank of Iceland) - Iceland (2022). Retrieved from cookiefines.eu
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