accountability - DPO Hub

EDPB Opinion 22/2024: obligations when relying on (sub-)processors

members – 8 min read

📚 You must list all (sub-sub-sub-sub...)processors (name, address, contact person, processing activity, roles & responsibilities) and always verify they've provided 'sufficient guarantees'—though the extent might vary based on risk—also for onwards transfers.

Oct 22, 2024

Norway DPA fines university for insufficient access control in MS Teams

members – 4 min read

The 🇳🇴 University of Agder was fined €12,500 (NOK 150k) for failing to secure personal data on Teams/SharePoint and insufficient internal controls. Short decision, several takeaways for everyone!

Sep 12, 2024

Denmark Google Workspace for Education Chromebook case (Helsingørgate)

members – 9 min read

[15 July: Municipalities complies with Jan order + 🚨 DPA asks for EDPB opinion on the scope of a controller's documentation obligations regarding a processor's use of sub-processors] The Danish DPA's landmark decision of 2022 to ban certain use of Google products and US transfers, is still ongoing.

Jul 15, 2024

Denmark DPA reports controller to police and suggests DKK 1,5 m fine

members – 2 min read

💸 DKK 1,5m and reported to the police for not auditing their processors for 𝒚𝒆𝒂𝒓𝒔, violating the accountability principle.

Feb 1, 2024

Denmark DPA orders municipalities to ensure Google-sharing compliance

members – 1 min read

🔥 Danish DPA with new decision in their Helsingørgate/Chromebook case!

Jan 30, 2024

CJEU C-231/22 Belgian State (Data processed by an official journal) 11 Jan 2024

members – 3 min read

National law can implicitly determine controllership, including for an official journal that only publishes data it receives, even when it doesn't have a legal personality on its own. (But note my comment on this.)

Jan 16, 2024

CJEU C-340/21 Natsionalna agentsia za prihodite (cybercrime) 14 Dec 2023

members – 7 min read

Unauthorised disclosure or access doesn't equate to inadequate measures, but must be proven to prevent damages claims. National courts must assess your case concretely and cannot systematically rely on expert reports. Mere fear = non-material damages (but must be proven by the data subject).

Jan 8, 2024