The European Data Protection Board (EDPB) recently published the draft Guidelines on Examples Regarding Data Breach Notification, a document that encompasses eighteen examples of data security incidents, on a spectrum of risk and necessary mitigating measures. Each example concludes with recommended actions based on the identified risks, mainly: recording the incident in the organization’s internal register, notifying the organization’s supervisory authority, and notifying affected individuals. The Guidelines are currently open for public consultation. The Guidelines include…
The Hamburg Commissioner for Data Protection and Freedom of Information (“Hamburg DPA”) imposed a 35.5 million Euro fine on a global fashion company’s subsidiary in Germany for violations of the GDPR. This million Euro fine is the highest fine known in Germany so far. It follows: the 14.5 million Euro fine imposed in October 2019 by the Berlin Commissioner for Data Protection and Freedom of Information (“Berlin DPA”) against a real estate company for violating…