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!
[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.
[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.
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.
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).