A breach happens. What now? When are you "aware", how do you assess the risk – and who do you need to notify? 📝 Homework: download the revised breach flowchart, tailor it to your organisation and ensure you have a step-by-step process in place.
[12 Feb: 🇩🇰 DPA webinar coming up!] [29 Jan: 🇩🇰 DPA applies dreaded EDPB Opinion and signal enforcement change. Must-read for 🇩🇰 folks but crucial to everyone using 🇺🇸 processors] Datatilsynet's landmark decision of 2022 to ban certain use of Google products and US transfers.
Weird DPA conclusion on controller's responsibility 🤔, will wait for the final decision | 🇳🇴 Datatilsynet notifies Helseplattformen of their intent to order fixes to serious organisational and (less serious) technical deficiencies.
After first flagging a fine with a potential starting point of £97m, the 🇬🇧 DPA heavily reduced it after several mitigating factors we can all learn from. A decision packed with practical lessons for DPOs, data protection and security teams alike!
UPDATE 1 Jan: Summary + full decision published! The DPC fines Meta for failing to safeguard users' passwords (storing them in plaintext!) and for notifying the breach too late.
⏰ Quickly deal with data breaches and listen to the DPA to reduce the chance of a fine (and keep access logs >3 months). DPAs aren't required to exercise a corrective power, like impose a fine, if not appropriate, necessary or proportionate to remedy the violation and ensure full GDPR compliance.
Meta failed to properly notify and document a breach affecting 3m EEA Facebook users and to build in data protection requirements throughout the design and development cycle.
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!
🇫🇷 Massive breach and what we can learn immediately from it: data minimisation, deletion, breach response plans - and communication that people actually understand!
This case is not only a goldmine for DPOs in the Swedish healthcare sector (although particularly so), but DPOs in general, for assessing roles, legal bases and processor liability.