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Denmark · Geography does not establish applicable law.
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Gyldendal A/S – Violation Found (Denmark, 2023)

Violation Found
Datatilsynet (Norway)13 April 2023Denmark
final
Violation Found

Privacy enforcement record

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Gyldendal A/S, a Danish publishing house, allowed teachers to access student test results through short URLs that could be guessed. This meant that unauthorized teachers could see personal information like names and emails. The ruling highlights the importance of securing personal data in educational tools.

What happened

Gyldendal A/S allowed unauthorized access to students' personal data through easily guessable URLs.

Who was affected

Students whose test results and personal information were accessed by unauthorized teachers.

What the authority found

The authority found that Gyldendal A/S did not take adequate security measures to protect personal data, violating GDPR's security requirements.

Why this matters

This case emphasizes the need for companies providing educational services to implement strong security measures. It serves as a reminder that even technical limitations cannot justify inadequate protection of personal data.

Recorded legal citations
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Art. 32(1) GDPR
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Art. 32(1) GDPR

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Linked-source text retrieved.

Automated check recorded — 18 March 2026.

Processing notes: authority corrected.

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Full Legal Summary
Detailed

The Danish publishing house Gyldendal A/S (the processor) offered a service to secondary education institutions. The service was used by teachers to create tests to screen students for their academic skill strengths and weaknesses. The tests were accessed with URLs and completed in a browser. The URLs providing access to the tests consisted of 8 characters in total of which 2 characters were randomised. In practice, this meant that a student – knowingly or unknowingly (e.g. as a result of mistyping the URL) – could complete a test set up by a teacher from another school. In this case, the teacher from another school would gain unauthorised access to the student's personal data (name, email and test results). The shortened URLs (with 8 characters) were specifically requested by the secondary education institutions (the controllers) whose IT systems did not allow longer URLs. It was assumed by the DPA, that teachers from other schools have indeed gained unauthorised access to students' test results, including the students' names and e-mails. As a result, the DPA found that a data breach pursuant to Article 4(12) GDPR had occured. It follows from Article 32(1) GDPR, that the processor must take appropriate technical and organisational measures to ensure a level of security appropriate to the risks included in the processor's processing activities. The DPA emphasised that access through URLs must take place in a way that ensures the confidentiality of personal data. The DPA viewed that a service clearly aiming to process and evaluate personal data about professional ability places great demands on the processor's design of their technical solution. URL manipulation was also considered a type of error source which is common knowledge and should be easily countered. Additionally, the DPA did not consider that technical limitations in a controller's IT setup could justify inadequate protection of the data subjects' rights. The DPA held that the publishing house violate

Outcome

Violation Found

The DPA found a violation but did not impose a fine.

Related Enforcement Actions (0)

No other enforcement actions found for Gyldendal A/S in DK

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

Details

Decision Date

13 April 2023

Authority

Datatilsynet (Norway)

GDPRhub ID

gdprhub-5939

About this data

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

Cite as: Cookie Fines. Gyldendal A/S - Denmark (2023). Retrieved from cookiefines.eu

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