principles - DPO Hub

🇮🇪 DPC fines TikTok €530m for China transfers

members – 2 min read

The Irish DPA also orders TikTok to bring their processing into compliance within six months. If they don't, they must stop the transfers. TikTok also breached transparency by failing to disclose the third countries involved and didn't explain the nature of the transfers in its privacy policy.

May 2, 2025

CJEU C-247/23 Deldits 13 Mar 2025

members – 2 min read

A Member State can't, under any circumstances, require a data subject to provide proof of gender reassignment surgery to exercise their right to rectification. However, they may need to provide relevant and sufficient evidence reasonably needed to show that the data is inaccurate.

Mar 13, 2025

CJEU C‑829/24 Commission v Hungary 12 Feb 2025 Order

members – 1 min read

The CJEU fast-tracks a case against Hungary where the European Commission claims violations of multiple EU laws, including the GDPR Articles 5, 6, 9 and 10.

Mar 13, 2025

🇮🇪 DPC fines LinkedIn €310m for illegal behavioural analysis and targeted advertising ('BA & TA')

members – 7 min read

Key takaways: Lack of lawful basis = loss of control = 'significant damage', lawful bases are notoriously tricky to get right, and most have lots to gain in improving information and transparency. Full decision = a key lesson on legitimate interest and LIAs.

Jan 22, 2025

CJEU C-394/23 Mousse 9 Jan 2025

members – 5 min read

Processing customers' titles to personalise communication based on gender isn’t essential for performing a contract; nor is it for a legitimate interest if they weren't informed beforehand, the processing isn't strictly necessary, or the balancing test goes in their favor.

Jan 13, 2025

CJEU C-65/23 K GmbH (Processing of employees’ personal data) 19 Dec 2024

members – 2 min read

While Article 88 allows for more specific national rules for processing personal data in the employment context, you still have to comply with Articles 5, 6 and 9 and can't lower the standard for or ignore the 'necessity' requirement.

Dec 22, 2024

noyb win: 🇳🇱 Dutch DPA fines Netflix €4.75m for lack of information

members – 1 min read

noyb gets their first big win in their streaming services complaint project, filed in January 2019 against Amazon Prime, Apple Music, DAZN, Flimmit, Netflix, SoundCloud, Spotify and YouTube. Unsurprisingly, Netflix has already objected.

Dec 19, 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

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

France DPA fines Amazon €32m for invasive employee monitoring

members – 3 min read

[22 March update: Amazon has appealed] The 🇫🇷 CNIL fined Amazon for excessively intrusive monitoring, using several illegal indicators and unsecure video surveillance software, without sufficiently informing employees and visitors.

Mar 22, 2024

Sweden MedHelp 1177 case

members – 8 min read

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.

Feb 22, 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