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The Spanish Data Protection Authority (“Agencia Espanola Proteccion Datos – AEPD”) has recently issued its highest fine to date, totaling €8.15 million for several breaches of GDPR and national legislation by a multinational telecommunication company and its service providers. Notably, €2 million of this fine was attributable to its service provider conducting an international transfer of personal data to a country that did not comply with the European data protection requirements.
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According to recent press reports, the German data protection authorities have agreed on a new way to calculate administrative fines under the General Data Protection Regulation (“GDPR”). The new scoring model, which has not yet been officially published, could make fines of tens of millions of euros a reality in Germany. In contrast to their French and UK counterparts, Germany’s data protection authorities have so far been more restrictive in imposing GDPR fines.
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In its second statement of intent of the week, on 9 July 2019, the UK’s Information Commissioner’s Office (“ICO”) announced its intention to fine Marriott International, Inc (“Marriott”) £99.2m under the General Data Protection Regulation (“GDPR”) for a personal data breach that occurred in relation to the Starwood guest reservation database system.
Continue Reading UK ICO Intends to Fine Marriott over £99m for Personal Data Breach under the GDPR

The UK’s Information Commissioner’s Office (“ICO”) today (8 July 2019) announced its intention to fine British Airways (“BA”) £183.39m under the General Data Protection Regulation (“GDPR”) for a personal data breach. This is the highest fine issued so far by a European Union data protection supervisory authority for a personal data breach under the GDPR. …
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According to recent press reports, since the EU General Data protection Regulation (GDPR) came into force in May 2018, German data protection authorities have issued 41 GDPR-related fines. The highest fine in a single case is reported to have been EUR 80,000, and the majority of fines (33) originated from the state of North-Rhine Westphalia.
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Although the EU General Data Protection Regulation (the “GDPR”) entered into force on 25 May 2018, and the obligations under the GDPR have since taken effect, there remain significant uncertainties as regards enforcement. In particular, the application of the GDPR’s fining provisions – arguably the key concern for companies commercially – raises several issues, …
Continue Reading GDPR Fines – Lessons from Competition Law

On 21 November 2018, the data protection authority of Baden-Württemberg, Germany (the “authority”) imposed a fine of EUR 20,000 against a German social media provider (the “company”) for failing to encrypt user passwords. The authority’s decision marks the first time that a fine was imposed on a company for violating the European General Data Protection Regulation …
Continue Reading Data Protection Authority Imposes First GDPR Non-Compliance Fine in Germany