Enforcing jurisdiction
Iceland · Geography does not establish applicable law.
Confirmed applicable legislation
Privacy topics

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

Complaint Upheld
Persónuvernd14 December 2022Iceland
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 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.

Recorded legal citations
Automatically processed
Art. 6 GDPR
Art. 5(1) GDPR
Art. 5(2) GDPR
Art. 32(1) GDPR
View original scraped data
Art. 5(1) GDPR
Art. 5(2) GDPR
Art. 6(GDPR)
Art. 32(1) GDPR

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

National Law Articles
AI-identified
Act no. 32/2009 Article 2(2)
Act no. 32/2009 Article 7(1(d))

Source checks

Linked-source text retrieved.

Automated check recorded — 23 March 2026.

Processing notes: articles corrected, 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

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

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

Cite as: Cookie Fines. Íslandsbanki (Bank of Iceland) - Iceland (2022). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: