A, B, C, D, E, F (data subjects) – €1,000 Fine (Greece, 2025)

In 2022 the DPA received six complaints from six (6) different data subjects, regarding the illegal disclosure of their personal data to ecclesiastical authorities by a natural person (controller). Three (3) of the data subjects were clergymen. In the course of a legal dispute between the controller and the six data subjects, the controller sent two complaint letters to several ecclesiastical officials and authorities (inter alia, two Archbishops, one Archimandrite and the General Hierarchical Commissioner of the Holy Metropolis). The conflict related to the controller's purchase of an apartment in a building in which the data subjects reside. Both letters of complaint were accompanied by numerous supporting documents containing a multitude of personal data of the six data subjects (home addresses, contact information, marital status, tax identification number, professional capacity, property details). According to the controller, the purpose of his letters of complaint was to provide the ecclesiastical authorities with full information, in order to discipline the three clergymen/data subjects by any appropriate means at their discretion, so that peace and tranquility may prevail in my home and in my personal life. Regarding the controller's claim that the above letters of complaint sent to the ecclesiastical authorities were part of a household activity, the DPA held that a submission before a body or authority (such as an ecclesiastical authority) entails at least the use and disclosure through transmission of personal data within the scope of Article 4(1) and (2) GDPR. The DPA found, that only two recipients of the complaint letters had any disciplinary authority relating to the controller's complaints over only three of the six data subjects. Thus, the DPA held, that * the transmission of the data of the three clergymen to all recipients and * the transmission of the data of the data subjects who do not have the status of clergy to any recipient was not ne