WORLD 2 MEET, S.L. – €70,000 Fine (Spain, 2025)

€70,000Agencia Española de Protección de Datos18 July 2025Spain
final
Fine

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 Controller offered booking services for tourism villas. As part of the check-in process, it was mandatory to verify the identity of the guests, in accordance with the local regulations. For this purpose, the Controller relied on an external platform operated by a partner, which was responsible for collecting a copy of each guest’s ID. Access to the platform was provided via a private link sent to the guest’s email address, outside the reservation platform. The data subject lodged a complaint regarding the processing of their ID, arguing that receiving the request through a private link posed a risk of unauthorised access and potential exposure of their personal data. The DPA found that requiring guests to upload a full copy of their ID through an external platform was unnecessary and disproportionate, violating the GDPR’s data minimisation principle under Article 5(1)(c). A complete ID card contains far more information than what is required by the applicable regulations, such as a photograph, expiration date, CAN, or parents’ names, and collecting this excess data introduces avoidable risks, including identity theft. Moreover, the DPA noted that an ID card alone does not provide all the information mandated by the applicable regulation and therefore cannot, by itself, fulfil its requirements. The purpose of the mentioned regulation is to safeguard people and property and maintain public order, given the role accommodation facilities may play in criminal activity. However, merely sending a copy of an ID document does not reliably verify a person’s identity and does not achieve this purpose. The DPA concluded that compliance with the applicable regulation can be achieved in a less intrusive way, for example, by having guests complete a form that collects only the specific data required under the regulation, whether online or in person. Collecting a full copy of an ID document therefore constitutes excessive processing and is not justified for the stated purpose

GDPR Articles Cited

Art. 4(1) GDPR
Art. 4(2) GDPR
Art. 4(7) GDPR
Art. 5(1)(c) GDPR
Art. 58(2)(d) GDPR
Art. 83(1) GDPR
Art. 83(2)(a) GDPR
Art. 83(2)(b) GDPR
Art. 83(2)(g) GDPR
Art. 83(5) GDPR
Art. 83(6) GDPR

National Law Articles

Annex I RD933/2021
Art.24 LO 4/2015
Art.4.3 RD 933/2021

Entities Involved

WORLD 2 MEET, S.L.
Data Subject
Company.1
Full Legal Summary

The Controller offered booking services for tourism villas. As part of the check-in process, it was mandatory to verify the identity of the guests, in accordance with the local regulations. For this purpose, the Controller relied on an external platform operated by a partner, which was responsible for collecting a copy of each guest’s ID. Access to the platform was provided via a private link sent to the guest’s email address, outside the reservation platform. The data subject lodged a complaint regarding the processing of their ID, arguing that receiving the request through a private link posed a risk of unauthorised access and potential exposure of their personal data. The DPA found that requiring guests to upload a full copy of their ID through an external platform was unnecessary and disproportionate, violating the GDPR’s data minimisation principle under Article 5(1)(c). A complete ID card contains far more information than what is required by the applicable regulations, such as a photograph, expiration date, CAN, or parents’ names, and collecting this excess data introduces avoidable risks, including identity theft. Moreover, the DPA noted that an ID card alone does not provide all the information mandated by the applicable regulation and therefore cannot, by itself, fulfil its requirements. The purpose of the mentioned regulation is to safeguard people and property and maintain public order, given the role accommodation facilities may play in criminal activity. However, merely sending a copy of an ID document does not reliably verify a person’s identity and does not achieve this purpose. The DPA concluded that compliance with the applicable regulation can be achieved in a less intrusive way, for example, by having guests complete a form that collects only the specific data required under the regulation, whether online or in person. Collecting a full copy of an ID document therefore constitutes excessive processing and is not justified for the stated purpose

Details

Fine Date

18 July 2025

Authority

Agencia Española de Protección de Datos

Fine Amount

€70,000

GDPRhub ID

gdprhub-9630

About this data

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

Cite as: Cookie Fines. WORLD 2 MEET, S.L. - Spain (2025). Retrieved from cookiefines.eu

Report Inaccuracy

Last updated: