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Telefónica Data Retention Fine (Spain)
Telefónica, a major Spanish telecommunications provider, maintained extensive traffic and location data of its subscribers for periods exceeding the limits specified under national implementations of EU directives. The company collected metadata including call records, IP addresses, and geolocation information from mil...
The Spanish Data Protection Agency (AEPD) conducted an investigation following complaints and audits, determining that Telefónica retained data for up to 12 months instead of the mandated 6 months for certain categories. A fine of €800,000 was imposed in 2015, with orders to revise data retention policies, implement au...
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["Telefónica S.A.", "Agencia Española de Protección de Datos (AEPD)"]
["Directive 2002/58/EC (ePrivacy Directive)", "Spanish Data Retention Law (LO 25/2007)", "GDPR Article 23 and Recital 119"]
None
Vodafone Data Retention Investigation (Germany)
Vodafone Germany operated public electronic communications networks and routinely retained subscriber metadata such as connection times, phone numbers, and IP logs to meet national requirements for criminal investigations. The retention practices involved storing data from over 40 million customers in secure databases ...
The Federal Commissioner for Data Protection and Freedom of Information (BfDI) investigated Vodafone's practices post the court ruling. No fine was issued, but Vodafone was directed to minimize retention to strictly necessary periods and pseudonymize data where possible. The company implemented new compliance framework...
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["Vodafone Germany", "Bundesbeauftragter für den Datenschutz und die Informationsfreiheit (BfDI)", "German Federal Constitutional Court"]
["Directive 2002/58/EC", "German Telecommunications Act (TKG)", "GDPR Article 5(1)(e)"]
2014
Orange Data Processing Compliance (France)
Orange, France's largest telecom operator, provides publicly available electronic communications services including mobile and fixed-line networks serving tens of millions of subscribers. In response to regulatory evolutions, Orange developed internal policies for handling traffic data solely for billing, interconnecti...
During a 2018 CNIL audit, Orange's practices were reviewed and found to adhere to retention limits, with robust access controls and audit logs. No enforcement actions were taken; instead, the audit report commended the operator's data minimization efforts as a model for the sector.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
COMPLIES
["Orange S.A.", "Commission Nationale de l'Informatique et des Libertés (CNIL)"]
["Directive 2002/58/EC", "French Data Retention Regime (Code de la sécurité intérieure)", "GDPR"]
None
British Telecom (BT) Metadata Retention Fine (UK)
BT, a leading UK telecom provider, retained communications metadata including call details and internet connection records for all subscribers under the Regulation of Investigatory Powers Act. The company stored this data in large-scale repositories to enable quick responses to law enforcement queries. An internal revi...
The UK Information Commissioner's Office (ICO) investigated in 2019, fining BT £530,000 for retaining data unlawfully post the EU Data Retention Directive invalidation. BT was required to delete excess data and enhance compliance monitoring.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["BT Group plc", "Information Commissioner's Office (ICO)"]
["Directive 2002/58/EC", "Regulation of Investigatory Powers Act 2000 (RIPA)", "UK Data Protection Act 2018", "GDPR"]
None
Deutsche Telekom Location Data Retention (Germany)
Deutsche Telekom, Germany's largest telecom operator, collected and stored cell tower location data as part of providing mobile services to over 40 million customers. This metadata was retained to support network optimization and legal access requests. Following legal challenges to data retention laws, the company face...
In 2020, the Hamburg Data Protection Authority fined Deutsche Telekom €9.5 million for retaining location data up to 14 days without sufficient basis under updated laws. The company was ordered to adjust retention to 72 hours maximum for most cases and appealed the decision unsuccessfully.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["Deutsche Telekom AG", "Hamburg Commissioner for Data Protection and Freedom of Information"]
["Directive 2002/58/EC", "German Telecommunications Telemedia Data Protection Act (TTDSG)", "GDPR Article 6"]
None
Vodafone Ireland Retention Compliance
Vodafone Ireland provides electronic communications services and maintains traffic data strictly for billing, customer service, and authorized law enforcement access as per Irish regulations. The company uses automated systems to retain connection data only for the minimum periods required—typically 2 years for billing...
The Data Protection Commission (DPC) conducted a 2021 sector-wide review and confirmed Vodafone Ireland's adherence through detailed documentation and system demonstrations. The operator received no sanctions and was noted for proactive compliance updates.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
COMPLIES
["Vodafone Ireland", "Data Protection Commission (Ireland)"]
["Directive 2002/58/EC", "Communications (Retention of Data) Act 2011", "GDPR"]
None
Telia Lithuania Metadata Breach
Telia, operating in Lithuania as a public electronic communications provider, experienced a security incident where retained subscriber metadata including phone numbers and connection timestamps was accessed improperly. The data, stored for compliance with national retention rules for over 3 million users, was kept in ...
The State Data Protection Inspectorate investigated in 2019, imposing a €120,000 fine for inadequate access controls on retained data. Telia enhanced security measures and reported the breach under GDPR requirements.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["Telia Lietuva", "State Data Protection Inspectorate of Lithuania"]
["Directive 2002/58/EC", "Lithuanian Law on Electronic Communications", "GDPR Article 32, 33"]
None
KPN Netherlands Compliance Program
KPN, a major Dutch telecom operator, serves millions with public communications networks and manages traffic data retention exclusively for service provision and legal obligations. The company established a comprehensive data governance framework with strict time-bound retention schedules—e.g., 7 months for internet me...
The Dutch Data Protection Authority (AP) audited KPN in 2022 as part of telecom sector oversight, verifying full alignment through logs and policies. KPN was recognized in the authority's report as exemplifying proper handling of ePrivacy obligations.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
COMPLIES
["KPN N.V.", "Autoriteit Persoonsgegevens (AP)"]
["Directive 2002/58/EC", "Dutch Telecommunications Act", "GDPR Recital 119"]
None
TIM Brasil ePrivacy Analog Fine (adapted EU context)
TIM Brasil, part of the Telecom Italia Mobile group with operations mirroring EU standards, retained call detail records and location data for subscribers in public networks. In a case paralleling ePrivacy rules, the company stored data beyond permitted periods for marketing analysis, affecting millions of users. This ...
Brazil's ANATEL and data authority investigated in 2017, fining TIM R$1.2 million (about €300,000) and mandating data deletion and policy overhauls. The case influenced EU group-wide reviews.
This Regulation shall not impose additional obligations on natural or legal persons in relation to processing in connection with the provision of publicly available electronic communications services in public communication networks in the Union in relation to matters for which they are subject to specific obligations ...
VIOLATES
["TIM Brasil", "ANATEL (Brazil)", "Telecom Italia (EU parent)"]
["Directive 2002/58/EC (analogous)", "GDPR", "Brazilian Internet Civil Rights Framework (Marco Civil)"]
None
Google LLC EU-US Transfers Fine by CNIL
Google LLC maintained data processing operations involving transfers of EU users' personal data, such as search history and advertising profiles, to the United States. Following the Schrems II judgment, the company continued relying on standard contractual clauses without fully implementing required supplementary measu...
The French data protection authority CNIL imposed a 150 million euro fine on Google in 2023 for non-compliance with GDPR international transfer rules. The decision was part of a coordinated EDPB taskforce action, leading Google to enhance its transfer tools with encryption and pseudonymization measures.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
VIOLATES
["Google LLC (data controller)", "CNIL (French supervisory authority)", "European Data Protection Board (coordinator)"]
["GDPR Articles 44-49", "Schrems II Judgment Requirements", "Standard Contractual Clauses (2021 version)"]
None
Meta Platforms Ireland SCC Compliance Adjustment
Meta Platforms Ireland Limited adjusted its international data transfer practices after the invalidation of Privacy Shield. The company had relied on pre-2016 transfer agreements and mechanisms for sending EU user data to the US, involving social media interactions, messages, and metadata processed by US affiliates. Po...
In a 2023 CJEU case (C-300/21), the validity of these updated SCCs was examined, resulting in an order for suspension of US transfers by the Irish DPC. Meta appealed, and the process highlighted ongoing efforts to align with evolving requirements, with temporary injunctions issued.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
VIOLATES
["Meta Platforms Ireland Limited", "Irish Data Protection Commission", "Court of Justice of the European Union"]
["GDPR Chapter V", "2021 Standard Contractual Clauses", "EU-US Data Privacy Framework (post-2023)"]
2016
British Airways Data Breach and Transfers
British Airways experienced a data breach in 2018 where hackers accessed payment card data and personal information of 400,000 customers. Some of this data was transferred to third-country processors for payment processing and analytics outside the EEA, relying on pre-GDPR agreements that were not fully updated to refl...
The UK Information Commissioner's Office (ICO) fined British Airways £20 million in 2020 (reduced from £183 million on appeal). Investigations revealed inadequate transfer mechanisms, prompting remediation including adoption of new SCCs and transfer impact assessments.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
VIOLATES
["British Airways (data controller)", "UK Information Commissioner's Office (ICO)"]
["GDPR Article 32 (security)", "GDPR Chapter V (transfers)", "Payment Card Industry Data Security Standard (PCI DSS)"]
2018
SAP SuccessFactors EU-US Transfers Compliance
SAP SE provides cloud-based HR software (SuccessFactors) to EU clients, involving transfers of employee personal data from the EEA to data centers in the United States. The company transitioned from Privacy Shield to the EU-US Data Privacy Framework (DPF) in 2023 and supplemented with technical measures like encryption...
SAP completed adequacy self-certification under DPF, underwent third-party audits, and published transfer impact assessments, maintaining uninterrupted service without enforcement actions related to transfers as of 2024.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
COMPLIES
["SAP SE (data processor/controller)", "EU Clients (data exporters)", "US Department of Commerce (DPF administrator)"]
["EU-US Data Privacy Framework", "GDPR Article 45 (adequacy)", "Standard Contractual Clauses"]
2023
Microsoft EU-US Cloud Transfers under DPF
Microsoft Corporation transfers EU customer data processed in Azure, Office 365, and other cloud services to US data centers. Following Schrems II, Microsoft developed the 'EU Data Boundary' solution, incorporating encryption, data residency controls, and commitments under the EU-US Data Privacy Framework to handle gov...
Microsoft self-certified under DPF in 2023, participated in EU adequacy decisions, and faced no major fines for transfers. The approach was endorsed in EU Commission adequacy decisions and used as a model for compliance.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
COMPLIES
["Microsoft Corporation", "European Commission", "Irish Data Protection Commission"]
["EU-US Data Privacy Framework", "GDPR Chapter V", "Cloud Infrastructure Transparency"]
None
Amazon AWS Transfer Mechanism Updates
Amazon Web Services (AWS) facilitates international data transfers for EU customers storing personal data in US regions. Pre-2020, reliance was on Privacy Shield; post-Schrems II, AWS rolled out AWS Account Processing Addendum incorporating updated SCCs, supplementary measures like client-managed keys, and support for ...
No enforcement actions against AWS for transfers; the company issued Data Processing Addendums signed by thousands of customers, enabling compliant cloud migrations without service disruptions.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
COMPLIES
["Amazon Web Services EMEA SARL", "EU Customers", "Luxembourg Data Protection Authority (CNPD)"]
["GDPR Article 28 (processor agreements)", "2021 Standard Contractual Clauses", "EU-US Data Privacy Framework"]
2020
Clearview AI Global Data Scraping Transfers
Clearview AI scraped billions of facial images from public websites worldwide, including EU sources, and transferred this biometric data to US servers for AI training and facial recognition services sold to law enforcement. Transfers lacked appropriate safeguards, relying on implied consents invalid under GDPR.
Multiple EU authorities, coordinated by CNIL, fined Clearview AI €20 million in 2022; ongoing bans on processing in several countries. The company ceased some EU operations but continued US-based activities.
International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force until amended, replaced or revoked.
VIOLATES
["Clearview AI Inc.", "CNIL (France)", "Dutch DPA", "Greek DPA"]
["GDPR Articles 44-49", "GDPR Article 9 (biometric data)", "EU AI Act (prospective)"]
None
Deloitte GDPR Fine for Email Exposure
In 2017, Deloitte, a multinational professional services network, experienced a configuration error on its guest Wi-Fi network at its London office. This misconfiguration allowed internet users to access approximately 700,000 emails containing sensitive personal data of over 100 clients, including passport details, NHS...
The ICO issued a £4.4 million fine to Deloitte in 2021, one of the largest under GDPR at the time, citing failures in basic security measures. Deloitte appealed the decision, but the fine was upheld following review.
Where reference is made to this paragraph, Article 5 of Regulation (EU) No 182/2011 shall apply. Where reference is made to this paragraph, Article 8 of Regulation ((EU) No 182/2011, in conjunction with Article 5 thereof, shall apply.
VIOLATES
["Deloitte LLP (data controller)", "Information Commissioner's Office (ICO, regulator)"]
["GDPR Article 32(1) (security measures)", "GDPR Article 5(1)(f) (integrity and confidentiality)", "GDPR Article 25(1) (data protection by design)"]
2017
Schrems II Case - Invalid Data Transfers
In 2013, privacy advocate Max Schrems filed a complaint against Facebook Ireland for transferring personal data of European users to servers in the United States. The complaint highlighted concerns regarding US government surveillance programs accessing EU personal data without sufficient safeguards. The Irish Data Pro...
On 16 July 2020, the CJEU ruled in Case C-311/18 that the EU-US Privacy Shield was invalid due to non-equivalence of protection levels. SCCs were upheld but required case-by-case assessments by exporters to ensure effective safeguards, leading to suspension of many transatlantic data transfers. Facebook ceased transfer...
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
VIOLATES
["Facebook Ireland", "Max Schrems (complainant)", "Irish Data Protection Commission (DPC)", "Court of Justice of the EU (CJEU)", "European Commission"]
["GDPR Article 45 (adequacy decisions)", "GDPR Chapter V (transfers to third countries)", "Directive 95/46/EC Article 25(6)"]
2013
European Commission First GDPR Report 2020
The European Commission conducted an evaluation of GDPR implementation two years after its entry into force on 25 May 2018. The report assessed overall application across EU Member States, focusing on data protection authorities' enforcement activities, fines imposed totaling over €500 million by mid-2020, and cooperat...
Published on 24 June 2020, the report concluded GDPR was functioning well but identified needs for guidance on emerging technologies and improved cooperation. No legislative proposals were made immediately, but it set the stage for future reviews. The report was submitted to the European Parliament and Council and made...
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
COMPLIES
["European Commission", "European Data Protection Board (EDPB)", "EU Member State Supervisory Authorities", "European Parliament", "Council of the EU"]
["GDPR Article 97 (reports by Commission)", "GDPR Chapter V (transfers)", "GDPR Chapter VII (cooperation and consistency)"]
May 2018
TikTok French CNIL Fine for Data Transfers
TikTok, operated by Douyin International in Europe, faced scrutiny over personal data processing of minors and international transfers. The French data protection authority (CNIL) investigated user data flows from EU users to servers in China and Singapore. Concerns arose from lack of transparency in transfer mechanism...
On 17 May 2024, CNIL imposed a €15 million fine for breaches including non-compliant data transfers to third countries. TikTok was ordered to update transfer tools and conduct impact assessments. The company appealed the decision.
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
VIOLATES
["TikTok (Douyin International)", "CNIL (French supervisory authority)", "European Data Protection Board (EDPB)"]
["GDPR Chapter V (transfers to third countries)", "GDPR Article 46 (SCCs)", "GDPR Article 97 (Commission evaluations)"]
None
Google Analytics Transfers - CNIL Orders Suspension
Multiple EU data protection authorities examined Google Analytics usage by websites for transferring EU user data to US servers via cookies and tracking tools. The CNIL initiated proceedings after complaints citing Schrems II requirements for supplementary measures. Investigations revealed standard Google contracts lac...
In June 2022, CNIL ordered French websites to stop data transfers to Google US, fining non-compliant entities. Google updated tools with EU-hosted options, but suspensions persisted in several countries pending full compliance.
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
VIOLATES
["Google LLC", "CNIL (France)", "Austrian DSB", "Italian Garante", "European Data Protection Board (EDPB)"]
["GDPR Chapter V (transfers)", "GDPR Article 46 (SCCs)", "GDPR Article 97(2)(a) (transfer evaluations)"]
None
EDPB Binding Decision on WhatsApp Cross-Border Processing
Meta's WhatsApp Ireland faced investigations from multiple supervisory authorities over data processing transparency and transfers for targeted advertising. The Irish DPC led the one-stop-shop mechanism under Chapter VII, but other authorities objected via the EDPB's consistency mechanism. The case involved extensive r...
In August 2023, the EDPB issued a binding decision mandating the Irish DPC to impose a fine and order WhatsApp to update processing records. A €225 million fine was issued in September 2023.
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
VIOLATES
["WhatsApp Ireland (Meta)", "Irish Data Protection Commission (DPC)", "European Data Protection Board (EDPB)", "Other EU Supervisory Authorities"]
["GDPR Chapter VII (cooperation and consistency)", "GDPR Chapter V (transfers)", "GDPR Article 97(2)(b)"]
None
European Commission 2024 GDPR Review Report
As required every four years, the Commission prepared its second major evaluation report on GDPR, covering the period up to 2024. It analyzed enforcement trends with fines exceeding €4 billion, effectiveness of transfer mechanisms post adequacy decisions like EU-US DPF, and Chapter VII cooperation via EDPB's 1000+ opin...
The report, submitted by early 2025, highlighted successes in enforcement but proposed no immediate amendments, recommending targeted guidance. It was publicized per requirements.
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
COMPLIES
["European Commission", "European Data Protection Board (EDPB)", "EU Supervisory Authorities", "European Parliament"]
["GDPR Article 97 (Commission reports)", "GDPR Chapter V", "GDPR Chapter VII"]
2024
Meta Platforms Ireland EDPB Urgency Procedure Transfers
Following Schrems II, Meta faced challenges with Facebook and Instagram data transfers to the US. The Irish DPC sought EDPB guidance under Chapter VII urgency procedure after NYOB complaints. The review assessed Meta's use of SCCs and new supplementary measures like encryption and pseudonymization against US laws.
In April 2023, EDPB ruled transfers unlawful, leading to Irish DPC suspension orders. Meta appealed to CJEU, ongoing as of 2024.
Commission reports. (1)By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public. (2)In the context of the evaluations and reviews referred to in paragraph 1, the Co...
VIOLATES
["Meta Platforms Ireland", "Irish DPC", "European Data Protection Board (EDPB)", "NOYB (complainant)"]
["GDPR Chapter V (transfers)", "GDPR Chapter VII (consistency)", "GDPR Article 97(2)"]
None
Schrems II and EU-US Privacy Shield Invalidated
In 2015, Max Schrems, an Austrian privacy activist, challenged the Safe Harbor framework, which had been used since 2000 for data transfers between the EU and US. Following the Court of Justice of the European Union (CJEU) ruling in October 2015 invalidating Safe Harbor due to concerns over US government surveillance p...
The CJEU in Case C-311/18 (Schrems II) on July 16, 2020, invalidated the Privacy Shield decision, finding it insufficient to ensure an essentially equivalent level of protection. The court upheld the use of Standard Contractual Clauses (SCCs) but mandated case-by-case assessments and supplementary measures. This led to...
Relationship with previously concluded Agreements. (1)International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force unt...
VIOLATES
["Max Schrems and noyb (complainant)", "Irish Data Protection Commission (supervisory authority)", "Court of Justice of the European Union (CJEU)", "European Commission", "US Department of Commerce"]
["GDPR Article 46(5)", "GDPR Chapter V (International Transfers)", "Privacy Shield Framework (2016)"]
2015
Meta (Facebook) EU-US Transfers Fine
Meta Platforms Ireland Limited handles EU user data for Facebook, Instagram, and WhatsApp, routinely transferring it to the US for processing, storage, and analytics. The company had relied on Privacy Shield until its invalidation, then shifted to the 2021 SCCs. A complaint by Max Schrems highlighted vulnerabilities to...
In May 2023, the Irish DPC fined Meta €1.2 billion for unlawful transfers, ordering data suspension and deletion. Meta appealed to Irish courts and implemented the EU-US Data Privacy Framework. EDPB issued binding decisions emphasizing supplementary measures.
Relationship with previously concluded Agreements. (1)International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force unt...
VIOLATES
["Meta Platforms Ireland (data controller)", "Irish Data Protection Commission", "European Data Protection Board", "Max Schrems/noyb"]
["GDPR Recital 101", "GDPR Article 46(1)", "2021 Standard Contractual Clauses"]
2021
Oracle Cloud Transfers Compliance Post-Schrems II
Oracle Corporation provides cloud infrastructure and SaaS services with data centers globally, including transfers from EU regions to the US. Prior to GDPR, it used model clauses; post-2016, it adopted Privacy Shield and transitioned to updated SCCs. Oracle serves enterprise clients in finance, healthcare, and governme...
No enforcement fines related to transfers. Oracle achieved CSA STAR certification and ISO 27001 compliance. In 2023, joined EU-US Data Privacy Framework. Regular third-party audits confirm adherence.
Relationship with previously concluded Agreements. (1)International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force unt...
COMPLIES
["Oracle Corporation", "National Data Protection Authorities", "Cloud Security Alliance"]
["GDPR Chapter V", "EU-US Data Privacy Framework", "ISO 27001"]
2016
Amazon AWS EU-US Transfers Scrutiny
Amazon Web Services (AWS) hosts EU customer data with options for regional storage but frequent transfers to US for backups, analytics, and support. Post-Schrems II, AWS faced complaints over default configurations enabling US access. It processes data for e-commerce, media, and public sector clients, using Nitro Encla...
Luxembourg CNPD investigated in 2022; AWS demonstrated supplementary measures, avoiding fines. Joined DPF in 2023 and offers AWS EU Sovereign Cloud.
Relationship with previously concluded Agreements. (1)International agreements involving the transfer of personal data to third countries or international organisations which were concluded by Member States prior to 24 May 2016, and which comply with Union law as applicable prior to that date, shall remain in force unt...
COMPLIES
["Amazon Web Services", "CNPD Luxembourg", "noyb"]
["GDPR Chapter V", "Schrems II Requirements"]
None
First GDPR Evaluation Report 2020
The European Commission conducted its first mandatory review of GDPR implementation as required by Article 97. The report assessed the regulation's effectiveness two years after entry into application, covering enforcement, data protection authorities' cooperation, international data transfers, and SME impacts. It drew...
Published on 24 June 2020, the report concluded GDPR was functioning well overall, with over 140,000 complaints and 500+ fines issued. It identified areas for improvement like one-stop-shop mechanism and proposed measures for enhanced cooperation without legislative changes.
By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public.
COMPLIES
["European Commission", "European Data Protection Board (EDPB)", "National DPAs"]
["GDPR Article 97 (reports)", "GDPR Recital 131"]
2020
EDPB Contribution to 2020 GDPR Review
The European Data Protection Board (EDPB), comprising heads of EU DPAs, provided input to the Commission's first GDPR evaluation report. It summarized enforcement trends, challenges in cross-border cases, resource needs for DPAs, and effectiveness of fines and corrective measures across member states.
In May 2020, EDPB adopted an opinion highlighting positive outcomes like increased awareness and €50 million in fines by early 2020. It recommended better funding for DPAs and simplification of procedures, influencing the Commission's report.
By 25 May 2020 and every four years thereafter, the Commission shall submit a report on the evaluation and review of this Regulation to the European Parliament and to the Council. The reports shall be made public.
COMPLIES
["European Data Protection Board (EDPB)", "European Commission", "National DPAs"]
["GDPR Article 97 (Commission report)", "GDPR Article 70 (EDPB tasks)"]
2020
European Commission Proposal for EDPB Regulation
The European Commission identified inconsistencies in data protection practices across Union institutions, bodies, offices, and agencies, particularly in how personal data processing was handled internally and in cross-border data flows within the EU. This stemmed from varying interpretations of GDPR applicability to p...
The proposal was submitted to the European Parliament and Council for adoption. It resulted in Regulation (EU) 2018/1725 being enacted, which standardized data protection rules for EU institutions and was implemented across all relevant bodies.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
COMPLIES
["European Commission (proposer)", "European Data Protection Supervisor (EDPS)", "European Parliament and Council (legislators)"]
["GDPR Article 97(1) and (2)", "Regulation (EU) 2018/1725"]
None
European Commission's GDPR Fitness Check
As part of its mandate under GDPR Article 97, the European Commission undertook a comprehensive fitness check of EU data protection legislation, evaluating its effectiveness in ensuring uniform protection across member states and institutions. The review highlighted discrepancies in how Union bodies processed personal ...
The Commission published a report recommending legislative proposals for consistency, leading to targeted amendments in acts like the Staff Regulations for EU employees' data handling. No fines were issued, but it prompted policy updates.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
COMPLIES
["European Commission (reviewer)", "National Data Protection Authorities"]
["GDPR Article 97(1)", "GDPR Evaluation Reports"]
2016
EDPS Formal Notice to European Commission on Data Transfers
The EDPS examined internal data transfer practices between EU institutions and third countries, finding inconsistencies in safeguards for personal data processed by bodies like the European Commission and shared with non-EU partners. This included transfers in the context of international cooperation projects where uni...
EDPS issued a formal notice in 2020, requiring the Commission to implement uniform transfer tools compliant with EU standards. The Commission complied by updating transfer mechanisms and reporting progress.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
VIOLATES
["European Data Protection Supervisor (EDPS)", "European Commission"]
["GDPR Article 97(2)", "Regulation (EU) 2018/1725 Chapter VII"]
None
Adoption of Regulation (EU) 2018/1725
Following identification of divergent data protection practices among EU institutions, the Commission proposed and legislators adopted Regulation (EU) 2018/1725, directly addressing the need for uniform rules on processing personal data by Union institutions, bodies, offices, and agencies. This regulation mirrored GDPR...
The regulation entered into force in December 2018, with full applicability by 2019. EU institutions integrated it into operations, leading to consistent compliance frameworks and reduced discrepancies.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
COMPLIES
["European Commission (proposer)", "European Parliament", "Council of the EU", "European Data Protection Supervisor"]
["GDPR Article 97(1)(b)", "Regulation (EU) 2018/1725"]
2018
EDPS Inquiry into EU Parliament Data Processing
An EDPS inquiry revealed variations in how the European Parliament processed personal data of staff and visitors, including non-standardized retention of biometric data and email metadata across departments. This created inconsistencies with other Union institutions' practices, impacting uniform protection and free mov...
The EDPS recommended alignment with emerging uniform standards in 2019, leading to Parliament-wide policy revisions and training programs.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
VIOLATES
["European Data Protection Supervisor (EDPS)", "European Parliament"]
["GDPR Article 97(2)", "Precursor to Regulation (EU) 2018/1725"]
None
European Commission's Proposal to Amend Staff Regulations
The Commission proposed amendments to the EU Staff Regulations to incorporate GDPR-aligned data protection rules for processing employee personal data across institutions. Prior inconsistencies included differing approaches to health data handling in occupational medicine services and performance evaluation records sha...
The proposal was adopted as Council Regulation (EU) 2021/407, updating data processing rules effective 2021, with institutions required to implement by specified deadlines.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
COMPLIES
["European Commission", "Council of the EU"]
["GDPR Article 97(1)", "Staff Regulations (Regulation No 31/62)"]
None
EDPS Decision on EU Council's Processing Practices
The EDPS reviewed the Council of the EU's handling of personal data in decision-making documents and internal databases, noting deviations from uniform standards applied by other institutions, such as prolonged retention of member state nominees' data without consistent anonymization protocols, affecting cross-institut...
In 2022, EDPS issued decisions mandating corrections, resulting in updated retention schedules and harmonized practices across Union bodies.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
VIOLATES
["European Data Protection Supervisor (EDPS)", "Council of the EU"]
["Regulation (EU) 2018/1725", "GDPR Article 97(2)"]
None
Implementation of Uniform DPIA Framework by EU Institutions
Following legislative proposals, EU institutions jointly developed and implemented a standardized Data Protection Impact Assessment (DPIA) framework for high-risk processing activities, such as AI-driven analytics on personal data shared between the Commission, Parliament, and agencies. This addressed prior ad-hoc appr...
The framework was rolled out in 2020, with annual compliance reports demonstrating consistent application and no major enforcement actions needed.
1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall in particular concern the rules relating to the protect...
COMPLIES
["European Commission", "European Parliament", "EDPS"]
["GDPR Article 97(1)", "Regulation (EU) 2018/1725 Article 39"]
None
Meta (Facebook) EU-US Data Transfers Fine
Meta Platforms Ireland Limited, the EU entity responsible for Facebook services in Europe, engaged in continuous transfers of personal data of EU users to the United States for processing by its US parent company and affiliates. Following the Schrems II ruling in 2020, which invalidated the Privacy Shield, Meta relied ...
In May 2023, the Irish DPC issued a final decision finding that Meta's transfers violated GDPR Chapter V requirements. A fine of 1.2 billion euros was imposed, the largest GDPR penalty to date. The DPC ordered Meta to cease transfers relying on the invalidated SCCs within five months and to delete data transferred unla...
In the context of the evaluations and reviews referred to in paragraph 1, the Commission shall examine, in particular, the application and functioning of: Chapter V on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) o...
VIOLATES
["Meta Platforms Ireland Limited", "Irish Data Protection Commission", "European Data Protection Board"]
["GDPR Chapter V", "GDPR Article 46", "Schrems II Judgment"]
2020
Adequacy Decision for United Kingdom
Following Brexit on January 31, 2020, the UK became a third country under GDPR. The UK had implemented the UK GDPR, mirroring EU GDPR, with the Information Commissioner's Office (ICO) as the supervisory authority. The EU evaluated the UK's protections, including independence of the ICO, data subject rights, and restric...
On June 28, 2021, the European Commission adopted an adequacy decision for the UK under Article 45(3), valid for four years initially with renewal options. This maintained seamless data flows post-Brexit.
In the context of the evaluations and reviews referred to in paragraph 1, the Commission shall examine, in particular, the application and functioning of: Chapter V on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) o...
COMPLIES
["European Commission", "UK Information Commissioner's Office", "European Data Protection Board"]
["GDPR Article 45(3)", "GDPR Chapter V", "UK GDPR"]
2020
Google Analytics Transfers to US (Austrian Case)
Several Austrian state data protection authorities investigated the use of Google Analytics by public bodies, which involved transferring IP addresses and other personal data to Google LLC in the US. Post-Schrems II, the tools were scrutinized for lacking sufficient safeguards against US surveillance, despite Google's ...
In January 2022, the Austrian Data Protection Authority ordered the city of Vienna to stop using Google Analytics, finding insufficient protection for data transfers. Similar findings occurred in other EU member states, leading to widespread suspension of the service.
In the context of the evaluations and reviews referred to in paragraph 1, the Commission shall examine, in particular, the application and functioning of: Chapter V on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) o...
VIOLATES
["City of Vienna", "Austrian Data Protection Authority", "Google LLC"]
["GDPR Chapter V", "Schrems II Judgment"]
None
Amazon France LogFiles Data Transfers
Amazon Europe Core SARL transferred personal data in logfiles from France to the US for security monitoring and fraud detection purposes. The French data protection authority (CNIL) examined the transfers after Schrems II, assessing whether SCCs and technical measures like encryption provided equivalent protection.
In August 2020, CNIL ordered Amazon to comply with GDPR transfer rules and imposed a 35 million euro fine in December 2022 for multiple violations, including inadequate transfer safeguards.
In the context of the evaluations and reviews referred to in paragraph 1, the Commission shall examine, in particular, the application and functioning of: Chapter V on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) o...
VIOLATES
["Amazon Europe Core SARL", "French CNIL"]
["GDPR Chapter V", "GDPR Article 46"]
None
European Commission Adequacy for South Korea
South Korea amended its Personal Information Protection Act (PIPA) in 2020 to enhance alignment with GDPR, including stricter consent requirements, data subject rights, and oversight by the Personal Information Protection Commission (PIPC). The EU conducted a thorough assessment of South Korea's framework, supplementar...
On December 17, 2021, the European Commission adopted an adequacy decision under Article 45(3) GDPR for South Korea, facilitating trusted data flows.
In the context of the evaluations and reviews referred to in paragraph 1, the Commission shall examine, in particular, the application and functioning of: Chapter V on the transfer of personal data to third countries or international organisations with particular regard to decisions adopted pursuant to Article 45(3) o...
COMPLIES
["European Commission", "South Korea Personal Information Protection Commission"]
["GDPR Article 45(3)", "GDPR Chapter V"]
2020
European Commission Proposal for Regulation (EU) 2018/1725
The European Commission identified inconsistencies between the General Data Protection Regulation (GDPR) applicable to private entities and the data protection framework governing Union institutions, bodies, offices, and agencies. Existing rules under Regulation (EC) No 45/2001 did not fully align with GDPR standards, ...
The Commission submitted a legislative proposal in 2017, which was adopted as Regulation (EU) 2018/1725 on 23 October 2018. This new regulation replaced Regulation (EC) No 45/2001, establishing the European Data Protection Supervisor (EDPS) as the independent supervisory authority with enhanced powers for investigation...
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
COMPLIES
["European Commission", "European Data Protection Supervisor (EDPS)", "European Parliament", "Council of the European Union"]
["Article 98 GDPR", "Regulation (EU) 2018/1725", "Regulation (EC) No 45/2001"]
2001
EDPS Investigation into EU Institutions' Data Processing (2019)
The European Data Protection Supervisor initiated a review following complaints and own-initiative inquiries into data processing practices by multiple EU institutions, including the European Commission and Parliament. Issues arose from large-scale processing of personal data in IT systems for human resources, procurem...
EDPS conducted audits and issued formal decisions in 2019-2020, requiring remedial actions such as system updates, staff training, and policy revisions. Institutions were mandated to align with Regulation (EU) 2018/1725 within specified timelines, with ongoing monitoring to ensure compliance. No fines were imposed as i...
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
VIOLATES
["European Data Protection Supervisor (EDPS)", "European Commission", "European Parliament"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
2019
European Commission's Proposal on Europol Data Processing (2022)
The European Commission reviewed Regulation (EU) 2016/794 governing Europol's processing of personal data, identifying misalignments with GDPR principles amid increasing data volumes from member states on serious crimes. Europol handled vast datasets including biometric data, criminal records, and victim information fr...
In 2022, the Commission proposed amendments adopted as Regulation (EU) 2022/884, enhancing data protection governance with a new oversight board, stricter retention rules, and mandatory data protection impact assessments. Europol updated its practices, improving compliance and data sharing efficiency.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
COMPLIES
["European Commission", "Europol", "European Parliament", "Council of the European Union"]
["Article 98 GDPR", "Regulation (EU) 2016/794 (amended by 2022/884)"]
2016
EDPS Corrective Measures on European Commission's Data Practices (2021)
Following a data breach in the European Commission's IT systems affecting personal data of thousands of individuals, the EDPS examined compliance with data protection rules. The incident involved unauthorized access to employee and stakeholder data in cloud-based services not fully compliant with Union standards. Broad...
EDPS issued a decision in 2021 imposing corrective measures, including suspension of non-compliant processing, enhanced training, and audits. The Commission remediated systems and reported full alignment by 2022.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
VIOLATES
["European Data Protection Supervisor (EDPS)", "European Commission"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
2021
Adoption of Data Protection Rules for EU Agencies (EBA Case)
The European Banking Authority (EBA), as a Union agency, underwent a review of its personal data processing for supervisory activities, whistleblower reports, and staff administration. Pre-2018, practices relied on outdated rules not mirroring GDPR, affecting data from banks, employees, and informants across EU states....
EBA implemented Regulation (EU) 2018/1725, appointing a Data Protection Officer and revising policies. EDPS verified compliance through 2020 audits, confirming uniform standards.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
COMPLIES
["European Banking Authority (EBA)", "European Data Protection Supervisor (EDPS)", "European Commission"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
2018
EDPS Inquiry into Parliament's Data Processing Systems (2020)
The European Parliament processed personal data via multiple IT platforms for member activities, visitor management, and public petitions, revealing gaps in uniform rights management and data minimization post-GDPR. Processing involved sensitive data from MEPs, staff, and citizens, with inconsistencies in cross-institu...
EDPS launched an inquiry in 2020, resulting in recommendations adopted by Parliament, including system overhauls and training programs to achieve consistency.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
VIOLATES
["European Data Protection Supervisor (EDPS)", "European Parliament"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
2020
European Commission's GDPR Alignment Review for ENISA
The European Union Agency for Cybersecurity (ENISA) processed personal data in cybersecurity incident reports and certification activities. A Commission-led review found discrepancies in handling threat intelligence data shared with member states, lacking full GDPR-equivalent safeguards for natural persons involved.
ENISA aligned operations with Regulation (EU) 2018/1725 via 2019-2021 updates, including privacy by design in tools. EDPS approved compliance in 2022.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
COMPLIES
["ENISA", "European Commission", "European Data Protection Supervisor (EDPS)"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
None
EDPS Decision on Council of the EU Data Processing (2022)
The Council processed personal data in legislative documents and security systems, with review uncovering non-uniform application of data subject rights and retention periods compared to GDPR standards, affecting data from negotiators and public consultations.
EDPS issued a 2022 decision requiring policy updates and audits; Council implemented changes, achieving alignment.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
VIOLATES
["European Data Protection Supervisor (EDPS)", "Council of the European Union"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
2022
Implementation of Uniform Rules at European Medicines Agency (EMA)
EMA processed clinical trial and pharmacovigilance data involving patient information from across the EU. The Commission's review ensured alignment of EMA's practices with GDPR for consistent protection in medicinal product authorizations.
EMA adopted Regulation (EU) 2018/1725, enhancing data anonymization and access controls; verified compliant by EDPS audits.
Review of other Union legal acts on data protection. (1)1:The Commission shall, if appropriate, submit legislative proposals with a view to amending other Union legal acts on the protection of personal data, in order to ensure uniform and consistent protection of natural persons with regard to processing. 2:This shall...
COMPLIES
["European Medicines Agency (EMA)", "European Data Protection Supervisor (EDPS)", "European Commission"]
["Article 98 GDPR", "Regulation (EU) 2018/1725"]
None
Schrems II Judgment 2020
Privacy activist Max Schrems challenged Facebook's data transfers to the US, highlighting US surveillance laws conflicting with EU protections. This built on prior litigation amid advancements in cloud computing and international data flows.
The Court of Justice of the EU invalidated the Privacy Shield in July 2020, requiring enhanced safeguards for transfers. Affected companies adopted new mechanisms like additional contractual protections.
The Commission shall, if necessary, submit appropriate proposals to amend this Regulation, in particular taking into account of developments in information technology and in the light of the state of progress in the information society.
VIOLATES
["Facebook (Meta)", "Irish DPC", "Court of Justice of the EU", "Max Schrems"]
["GDPR Chapter V", "EU-US Privacy Shield", "Standard Contractual Clauses"]
2020
GDPR One-Stop-Shop Mechanism Success
The GDPR's one-stop-shop allows lead supervisory authorities to handle cross-border processing, demonstrated in coordinated actions against Big Tech firms. This mechanism adapted to multinational digital services expanding via cloud and AI technologies.
The EDPB's binding decisions, such as in Meta cases, streamlined enforcement, resulting in consistent fines and compliance improvements across member states.
The Commission shall, if necessary, submit appropriate proposals to amend this Regulation, in particular taking into account of developments in information technology and in the light of the state of progress in the information society.
COMPLIES
["European Data Protection Board (EDPB)", "National DPAs", "Multinational Companies (e.g., Meta, Google)"]
["GDPR Article 56 (One-Stop-Shop)", "GDPR Article 63 (Cooperation Mechanism)"]
None
Google Analytics and Google Ads Fine by CNIL
France's data protection authority, CNIL, examined the use of Google Analytics and Google Ads tools on websites of data controllers in France. The tools involved transfers of personal data to the US without adequate safeguards, such as standard contractual clauses that did not sufficiently protect data against US surve...
Following formal notices and non-compliance, CNIL imposed a €150 million fine on Google LLC in 2022, the largest GDPR fine to date in France. The decision followed complaints from privacy organizations like None of Your Business (NOYB). Google adjusted its practices but contested the fine legally.
For the purpose of paragraph 1, the Commission may request information from Member States and supervisory authorities.
VIOLATES
["Google LLC (data processor/controller)", "CNIL (French supervisory authority, regulator)", "None of Your Business (NOYB, complainant)"]
["GDPR Article 44-50 (transfers to third countries)", "GDPR Chapter V (international transfers)", "GDPR Article 58 (powers of supervisory authorities)"]
None
DPC Inquiry into WhatsApp Ireland
WhatsApp Ireland Limited was investigated for transparency in its privacy policy updates in 2021, which shared user data with Meta companies for advertising. The inquiry examined compliance with information obligations for over 500 million EU users.
The Irish DPC, following complaints from NOYB, fined WhatsApp €225 million in 2021 (reduced to €205 million on appeal in 2023). EDPB issued binding decisions to ensure uniform application.
For the purpose of paragraph 1, the Commission may request information from Member States and supervisory authorities.
VIOLATES
["WhatsApp Ireland Limited (data controller)", "Irish Data Protection Commission (DPC)", "European Data Protection Board (EDPB)", "NOYB (complainant)"]
["GDPR Article 13-14 (information to data subjects)", "GDPR Article 5(1)(a) (transparency)", "GDPR Article 12"]
2021
H&M Data Processing Staff Data Fine
H&M Sweden AB's Nuremberg store created 'welcome back talks' where returning employees shared colleagues' private information overheard during absences, stored in HR systems without consent or transparency. This affected German employees.
Hamburg DPA fined €35.25 million in 2023 after own-volition investigation. The fine reflected systematic nature and large data volumes processed.
For the purpose of paragraph 1, the Commission may request information from Member States and supervisory authorities.
VIOLATES
["H&M Sweden AB (data controller)", "Hamburg Supervisory Authority (German DPA, regulator)"]
["GDPR Article 5(1)(a),(b) (lawfulness, fairness, transparency)", "GDPR Article 6 (legal basis)", "GDPR Article 88 (data protection in employment)"]
None
Microsoft GDPR Settlement with CNIL
Microsoft's services, including Windows telemetry and advertising technologies, collected extensive personal data from EU users such as location, diagnostics, and browsing history. Consent mechanisms were found non-granular, and data transfers to the US lacked adequate protections post-Schrems II.
CNIL imposed a €60 million fine in 2023 after complaints. Microsoft agreed to modifications, including improved consent banners and EU-based processing options. This was part of broader Privacy Shield successor arrangements scrutiny.
In carrying out the evaluations and reviews referred to in paragraphs 1 and 2, the Commission shall take into account the positions and findings of the European Parliament, of the Council, and of other relevant bodies or sources.
VIOLATES
["Microsoft Ireland Operations (data controller)", "CNIL (regulator)", "NOYB (complainant)"]
["GDPR Article 7 (conditions for consent)", "GDPR Article 49 (derogations for transfers)", "ePrivacy Directive (cookies)"]
None
Meta Platforms Repeated Fines
In 2023, Ireland's Data Protection Commission (DPC) investigated Meta's processing of EU users' personal data for behavioral advertising following the invalidation of EU-US Privacy Shield. Meta continued transfers relying on Standard Contractual Clauses without sufficient supplementary measures to protect data from US ...
The European Data Protection Board (EDPB) issued a binding decision leading to a €1.2 billion fine in May 2023, the largest GDPR penalty to date. Meta suspended transfers, implemented new safeguards, and appealed the decision.
This Regulation shall enter into force on the twentieth day following that of its publication in the Official Journal of the European Union.
VIOLATES
["Meta Platforms Ireland Ltd.", "Irish Data Protection Commission (DPC)", "European Data Protection Board (EDPB)"]
["General Data Protection Regulation (GDPR) Chapter V", "GDPR Article 46"]
2023