City of Reykjavik – Complaint Upheld (Iceland, 2023)
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 data protection authority found that Reykjavik city mishandled a child's health report by emailing it to the wrong person, along with the password to open it. The authority noted that sending the password with the document did not protect the data. This case stresses the importance of secure data handling practices.
What happened
Reykjavik city sent a child's health report to the wrong email address, including the password to open it.
Who was affected
A child whose health report was mistakenly sent to an unauthorized recipient.
What the authority found
The Icelandic DPA found Reykjavik city failed to secure personal data as required by GDPR Article 32.
Why this matters
This incident underscores the need for robust data protection measures, especially when handling sensitive information. Organizations should ensure secure communication practices to prevent unauthorized access.
GDPR Articles Cited
The city of Reykjavik (controller) sent a health report about a child to the wrong person by email. The document was locked but the password to open it was sent to the same wrong email address. The recipient reported the error on the same day he received the e-mail. The controller reported the data breach to the DPA as a security breach within 72 hours, explaining that the breach was due to a human error when entering the email address. The controller also informed the parents of the child that their child’s data had been disclosed to an unauthorised recipient and contacted the latter asking him to delete the emails. The parents considered that the controller did not implement technical and organizational measures in order to ensure the security of personal data. Therefore, they filed a complaint with the DPA. In its defence, the controller argued that it had appropriate measures in place since the document was locked with a password, that it reported the data breach to the DPA and notified the parents. The DPA first stressed that the sending per email of a locked report containing health information to an unauthorised party, along with the password to unlock the document constitutes processing of personal data pursuant to Article 4 GDPR. The DPA explained that locking the document was useless since the password was communicated in the same way as the document, i.e. in contiguous e-mails to the same e-mail address. The controller therefore did not ensure the security of the data as required by Article 32. Taking into account that the controller reported the breach as required by Article 34, notified the parents and contacted the recipient of the report for its deletion, the DPA stated that there was no reason for further action. It did not consider necessary to fine the controller or to order special measures.
Outcome
Complaint Upheld
A data subject complaint that was upheld by the DPA.
Related Enforcement Actions (1)
Other enforcement actions involving City of Reykjavik in IS
Details
About this data
Cite as: Cookie Fines. City of Reykjavik - Iceland (2023). Retrieved from cookiefines.eu
Last updated: