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Description

The Luxembourg DPA has imposed a fine of EUR 15,400 on a company. According to the DPA, the controller failed to involve the data protection officer in all matters related to the protection of personal data. In addition, contrary to the requirements of the GDPR, the data protection officer did not report directly to the highest management level; instead, there were two levels of hierarchy in between. Also, the controller did not have a data protection control plan in place to demonstrate that the data protection officer was performing their duties appropriately.