Company

€18,700

Insufficient involvement of data protection officer

决定日期

2021年10月27日

权力

National Commission for Data Protection (CNPD)

LU

部门

Industry and Commerce

国家

HU

法律

GDPR

现状

FINAL

说明

The DPA of Luxembourg has imposed a fine of EUR 18,700 on a company. During its investigation, the DPA first found that the controller's public website did not include direct contact details for the DPO. Furthermore, the DPO was not sufficiently involved in all data protection matters. For example, they only participated in internal meetings by invitation. Moreover, there were several hierarchical intermediaries between the DPO and the highest management level of the controller, not granting them sufficient autonomy. Also, in the absence of formalized procedures, the DPO was not able to sufficiently monitor the consistency of data processing practices.

法律引文

Art. 37 (7)Art. 38 (1)Art. 39 (1)

问题与违规

Insufficient involvement of data protection officer

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