controller - 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

CJEU C-200/23 Agentsia po vpisvaniyata

members – 3 min read

An authority of a commercial register = both recipient and controller. Handwritten signatures = personal data. Temporary loss of control (e.g. public disclosure) can lead to damage, but harm must be proven. And a few more points in today's CJEU ruling!

Oct 4, 2024

Italy: bank fined €1m and rental company €250k for unclear DPAg and no legal basis

members – 4 min read

The 🇮🇹 Garante fined a bank €1 million for anti-fraud checks as a processor on behalf of a group company without a legal basis, breaching both Articles 28(3) and 5(1)(a). The rental company was separately fined €250,000, also for an insufficient privacy notice. Here are your key takeaways! 💡

Aug 21, 2024

CJEU C-461/22 MK (legal guardian)

members – 1 min read

A former legal guardian who acted in a professional capacity is a controller and must comply with the GDPR, including the right of access.

Jul 14, 2024

Dutch DPA on education sector social media marketing

members – 4 min read

The DPA stresses that their advice applies generally to all social media and "of great importance" to all educational institutions and similar organisations in 🇳🇱.

Jun 17, 2024

🚨 CJEU confirms TC String as personal data and IAB Europe as joint controller

members – 1 min read

DPO Hub writeup coming soon!

Mar 7, 2024

CJEU C-231/22 Belgian State

members – 3 min read

Controllership can be determined implicitly from national law, even for an official journal that only publishes data as it receives, including when that journal doesn't have a legal personality (but note my comment on this!).

Jan 16, 2024

CJEU C‑683/21 Nacionalinis visuomenės sveikatos centras

members – 4 min read

The definition of 'controller' is broad and you're liable for all processing, done directly or by others on your behalf, including processors. Joint controllership is determined by facts, not contracts. Know your role(s)!

Jan 6, 2024

CJEU C-807/21 Deutsche Wohnen

members – 3 min read

The definition of 'controller' is broad and includes legal persons, who are liable for any violations committed by any person in their business who act on their behalf. DPAs must demonstrate that you acted with intent or neglect to fine you and must base the max amount on the group's total revenue.

Jan 5, 2024