Company
Insufficient involvement of data protection officer
決定日期
2021年10月27日
權限
National Commission for Data Protection (CNPD)
LU
部門
Industry and Commerce
國家
HU
法律
GDPR狀態
FINAL說明
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.