City of Reykjavik

€13,300

Non-compliance with general data processing principles

Decision Date

December 6, 2023

Authority

Icelandic data protection authority ('Persónuvernd')

IS

Sector

Public Sector and Education

Country

IS

Law

GDPR

Status

FINAL

Description

The Icelandic DPA has imposed a fine of EUR 13,300 on the city of Reykjavik. The city had used the Google Education system in schools without sufficiently complying with data protection regulations. In particular, the city did not fulfill its obligations when selecting Google as a processor and the processing agreement with Google did not comply with data protection requirements. Furthermore, the city did not ensure that the student data was not processed for purposes other than those specified by the city. In imposing the fine, particular consideration was given to the protection of sensitive children's data. Although no demonstrable damage had occurred, it was criticized that the city had not sufficiently ensured the secure transfer of data to the US in the past. However, the municipality cooperated transparently with the data protection authority and revised its data protection practices.

Legal Citations

Art. 5 (1)Art. 24 (1)Art. 28

Issues & Violations

Non-compliance with general data processing principles

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