ARTICLE
21 December 2023

GDPR Enforcement: November 2023

SJ
Steptoe LLP

Contributor

In more than 100 years of practice, Steptoe has earned an international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Steptoe has more than 500 lawyers and professional staff across the US, Europe and Asia.
1. Agencia Española de Protección de Datos (Spain) 2. Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Persona (Romania)...
United States Privacy
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Top 3 Most Active Regulators by Volume of Fines

1. Agencia Española de Protección de Datos (Spain)

2. Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Persona (Romania)

3. The Information Commissioners Office (UK)

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Top 3 Most Active Regulators by Value of Fines

1. Datatilsynet (Norway)

2. Agencia Española de Protección de Datos (Spain)

3. The Information Commissioners Office (UK)

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Top 3 Most Active Regulators by Volume of Fines

1. Agencia Española de Protección de Datos (Spain)

2. Garante per la protezione dei dati personali (Italy)

3. Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal (Romania)

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Top 3 Most Active Regulators by Value of Fines

1. Data Protection Commission (Ireland)

2. Commission Nationale de l'Informatique et des Libertés – CNIL (France)

3. The Information Commissioners Office (UK)

Top Fine

  • The Norwegian DPA, Datatilsynet, issued a fine of approx. €1.7 million against the Norwegian Labour and Welfare Administration (NAV).
  • The main ground for this sanction relates to unsatisfactory "technical and organisational" measures implemented by NAV.
  • Datatilsynet is known to be a very stringent data protection authority and this case is a new demonstration that this data protection authority is not more lenient towards public authorities.
  • It must be noted that NAV was already sanctioned in 2022 for lack of legal basis, which may explain the high-level value of this new fine.
  • The NAV will have an opportunity to comment on the allegations and potentially have the proposed fine reduced.

Key Takeaways

  • Thus far, November has been the quietest month in 2023 in terms of GDPR enforcement, with a limited volume and value of fines imposed.
  • Lack of legal basis for sending marketing communications remains a key concern for European regulators, as illustrated by the fines imposed by the UK's DPA to three companies.
  • The Spanish DPA, AEPD, remains by far the most active regulator and continues to impose fines limited in value.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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ARTICLE
21 December 2023

GDPR Enforcement: November 2023

United States Privacy

Contributor

In more than 100 years of practice, Steptoe has earned an international reputation for vigorous representation of clients before governmental agencies, successful advocacy in litigation and arbitration, and creative and practical advice in structuring business transactions. Steptoe has more than 500 lawyers and professional staff across the US, Europe and Asia.
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