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ICS – €150,000 Fine (Netherlands, 2023)

€150,000Autoriteit Persoonsgegevens18 December 2023Netherlands
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Fine

Privacy enforcement record

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The Dutch Data Protection Authority fined ICS EUR 150,000 for not conducting a required data protection impact assessment before launching a new identification tool. This is important because it shows that companies must evaluate risks to user privacy before implementing new technologies. Failing to do so can lead to significant financial penalties.

What happened

ICS was fined for not conducting a data protection impact assessment before introducing its ID&V identification system.

Who was affected

Customers of ICS who were affected by the identification and verification tool.

What the authority found

The authority ruled that ICS failed to assess the risks of its data processing operations, violating GDPR requirements.

Why this matters

This case highlights the necessity for companies to perform risk assessments when processing personal data. It serves as a reminder that neglecting these responsibilities can result in hefty fines.

Recorded legal citations
Automatically processed
Art. 35 GDPR
Art. 35(1) GDPR
Art. 35(7) GDPR
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Art. 35 GDPR
Art. 35(1) GDPR
Art. 35(7) GDPR

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Full Legal Summary
Detailed

Following a series of reports and complaints against ICS, a subsidiary of ABN AMRO, as a controller, the Dutch DPA (Autoriteit Persoonsgegevens, AP) decided to start an ex officio investigation into the processing operations carried out by the controller. The AP mainly received complaints concerning the controller's process of re-identifying its customers online by means of a new identification and verification tool, ID&V. The AP found that the controller never conducted a DPIA in 2018, prior to the introduction of its identification system, and asked the controller to provide its submissions on this. The controller claimed in this respect that it did not need to carry out a DPIA, since the same identification system was used by ABN AMRO before, and ABN AMRO had previously carried out a risk assessment of its own authentication app. Moreover, the controller argued that when ID&V was introduced, there were no risks of potential misuse of personal data, and strict security measures were in place. Also, the controller argued that the only criterion that suggested the need to carry out a DPIA, according to Article 35 GDPR, was the fact that the processing was large-scale, but no other criteria were given that would make its processing activities "high risk". Lastly, the controller claimed that it does not process any special categories of personal data within the meaning of Article 9 GDPR. The AP first of all assessed whether the controller’s processing operations presented a high risk to the rights and freedoms of natural persons. The AP made this assessment in light of [https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&cad=rja&uact=8&ved=2ahUKEwj5rKOm5PODAxUBbvEDHTkrDysQFnoECBAQAQ&url=https%3A%2F%2Fec.europa.eu%2Fnewsroom%2Fdocument.cfm%3Fdoc_id%3D47711&usg=AOvVaw0fHA9krZ_2-wSysNMXoIyB&opi=89978449 Article 29 Working Party Guidelines 248 rev.01 on “Data Protection Impact Assessment (DPIA) and determining whether processing is ‘likely to result in a high

Related Enforcement Actions (0)

No other enforcement actions found for ICS in NL

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

Details

Fine Date

18 December 2023

Authority

Autoriteit Persoonsgegevens

Fine Amount

€150,000

About this data

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

Cite as: Cookie Fines. ICS - Netherlands (2023). Retrieved from cookiefines.eu

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