Who was sanctioned, and for what?

A processor of Berlin's public transport operator BVG, which had sent customer letters in early 2025, was hacked; around 180,000 customer records were affected, although they should long since have been deleted after the end of the contract. BVG had never checked the deletion, had not agreed any procedure for data breaches in the data processing agreement and reported the incident only after the 72-hour deadline had expired; the Berlin Commissioner for Data Protection and Freedom of Information (BlnBDI) issued a reprimand.

Authority / court

Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)

Area of law

Data protection · Data processors

Legal basis

Art. 5 Abs. 2 i. V. m. Abs. 1 lit. c, e, f, Art. 28 Abs. 3 S. 2 lit. f, Art. 32 Abs. 1, Art. 33 DSGVO

Action

Reprimand or warning

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Mitigating circumstances

BVG has announced measures against similar incidents.

Published

4 May 2026

Checked against the official source on 25 Sep 2026 · Direct link

The starting point was a complaint about incomplete disclosure of patient data; the clinic left several requests from the supervisory authority unanswered. The Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, AKI) ordered it to revise its contracts with Align Technology (Invisalign) with regard to the GDPR roles (Art. 26/28 GDPR), to adapt the consent form and the privacy notices in accordance with Art. 7, 9, 13 and 14 GDPR and to publish them in Estonian; non-compliance is subject to a penalty payment of 1,000 EUR per item.

Authority / court

Andmekaitse Inspektsioon (AKI)

Area of law

Data protection · Data processors

Legal basis

§ 56 Abs. 1 IKS; Art. 58 Abs. 2 lit. d DSGVO i. V. m. Art. 5 Abs. 1 lit. a, 7, 9, 13, 14, 26, 28 DSGVO

Action

Order

Status of proceedings

unknown

Sector

Healthcare

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

The management corporation of the Riverfront Residences condominium had not designated a data protection officer until March 2025, had no data protection policies of its own and had given its managing agent, which acted for it as a data intermediary, no instructions on handling personal data; in April 2025 an employee of the managing agent mistakenly sent the names, addresses and maintenance fee details of two owners to another owner. The Personal Data Protection Commission (PDPC, Singapore's data protection authority) found breaches of the Accountability Obligation and the Protection Obligation; by contrast, it found no breach in the circulation of a requisition for an extraordinary general meeting bearing the names and signatures of 303 owners, because strata management law prevailed. It directed the corporation to introduce, within 90 days, policies and procedures for the processing of data by the managing agent and to communicate them to it; the managing agent itself had given a voluntary undertaking.

Authority / court

Personal Data Protection Commission (PDPC)

Area of law

Data protection · Data processors

Legal basis

Sections 11(3) und 12(a) PDPA 2012 (Accountability Obligation); Section 24 i. V. m. Section 4(3) PDPA (Protection Obligation bei Einsatz eines Data Intermediary)

Action

Order

Status of proceedings

unknown

Sector

Construction and real estate

Published

7 May 2026

Checked against the official source on 4 Oct 2026 · Direct link

In an attack on an application operated by a processor, data of a very large number of persons (including personal identification numbers, driving licence and identity card numbers, vehicle identification numbers) were stolen and published. The Romanian data protection authority (ANSPDCP) criticised the lack of security measures and effectiveness testing as well as the selection of a service provider without sufficient guarantees and imposed 637,262.50 lei (125,000 EUR).

Authority / court

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP)

Area of law

Data protection · Data processors

Legal basis

Art. 32 Abs. 1 lit. b und d, Abs. 2 i. V. m. Art. 28 Abs. 1 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Automotive

Published

25 Mar 2026

Original amount 637,262.5 RON, converted at the ECB reference rate of 25 Mar 2026.

Checked against the official source on 25 Sep 2026 · Direct link

The UODO (Urząd Ochrony Danych Osobowych, Polish data protection authority) fined the parcel carrier DPD Polska sp. z o.o. a total of PLN 11,461,030. PLN 6,251,471 relates to the company using external hauliers for shipments between its depots without a data processing agreement under Art. 28(3) GDPR, although they had access to the address labels during loading and unloading; PLN 5,209,559 relates to staff not being given effective authorisations to process data and the company's own data protection policy not being implemented (Art. 24, 29, 32 GDPR). The authority classed both infringements as intentional and treated earlier reprimands against the company as aggravating. The decision is not final.

Authority / court

Prezes Urzędu Ochrony Danych Osobowych (UODO)

Area of law

Data protection · Data processors

Legal basis

Art. 28 Abs. 3 i. V. m. Art. 5 Abs. 1 lit. a und Abs. 2 DSGVO; Art. 24 Abs. 1 und 2, Art. 29, Art. 32 Abs. 1 und 4 i. V. m. Art. 5 Abs. 1 lit. f und Abs. 2 DSGVO; Art. 83 Abs. 4 lit. a und Abs. 5 lit. a DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Transport, logistics and shipping

Culpability

intentional

Repeat case

yes

Mitigating circumstances

It was treated as mitigating that, after the proceedings were opened, DPD amended its contracts with the hauliers to include data processing terms and changed its procedure for granting authorisations.

Liability of senior managers

No personal liability was established.

Published

23 Feb 2026

Original amount 11,461,030 PLN, converted at the ECB reference rate of 5 Feb 2026.

Checked against the official source on 28 Sep 2026 · Direct link

The provider of cloud-based HR software received an extortion email in April 2024; an attacker had deleted databases on its AWS servers and likely exfiltrated data, and data allegedly taken was offered for sale on the dark web – data on 95,000 employees of its clients (including identity number, salary, bank account and religion) and on 24,765 emergency contacts and children was put at risk. The Personal Data Protection Commission (PDPC, Singapore's data protection authority) found a breach of the Protection Obligation because, despite the HR data entrusted to it by clients, the provider had no web application firewall against existing SQL injection vulnerabilities, remote desktop access open to the internet without two-factor authentication, and vulnerability scans only every two years. It imposed 17,500 SGD, payable in twelve monthly instalments in view of the company's cash flow, and directed among other things a web application firewall, annual penetration tests, two-factor authentication and encryption of all personal data fields.

Authority / court

Personal Data Protection Commission (PDPC)

Area of law

Data protection · Data processors

Legal basis

Section 24 PDPA 2012 (Protection Obligation); Section 48J PDPA (Financial Penalty)

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Repeat case

no

Mitigating circumstances

Cooperation, admission under the Expedited Decision Procedure and first breach; payment in instalments in view of cash flow, while a waiver was refused.

Published

8 Jan 2026

Original amount 17,500 SGD, converted at the ECB reference rate of 8 Jan 2026.

Checked against the official source on 4 Oct 2026 · Direct link

In August 2024 an attacker encrypted a network drive shared by SESAMi and its subsidiary Abecha holding payment data (including full credit card numbers and bank account details) of around 20,471 customers of the subsidiary's fuel fleet discount programme and of up to 18,837 individuals from registrations for SESAMi's B2B platform; exfiltration could not be established. The Personal Data Protection Commission (PDPC, Singapore's data protection authority) classified SESAMi, which ran the network for the subsidiary without a written contract, as a data intermediary in that respect and found a negligent breach of the Protection Obligation by SESAMi (including outdated firewall and VPN firmware, no patch management and unenforced password and MFA rules), and likewise by Abecha, which as controller had taken no steps to ensure adequate security at SESAMi. SESAMi received 8,750 SGD and directions, while Abecha, as the controller, received directions only, including setting out roles and data protection duties within the group in writing.

Authority / court

Personal Data Protection Commission (PDPC)

Area of law

Data protection · Data processors

Legal basis

Section 24(a) PDPA 2012 (Protection Obligation); Section 4(3) PDPA (Pflichten bei Einsatz eines Data Intermediary); Section 48J PDPA (Financial Penalty)

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Culpability

negligent

Mitigating circumstances

Cooperation, prompt and effective remediation, admission under the Expedited Decision Procedure; for Abecha also lower culpability owing to its limited autonomy as a wholly owned subsidiary, one of the reasons for not imposing a fine on it.

Published

26 Feb 2026

Original amount 8,750 SGD, converted at the ECB reference rate of 29 Dec 2025.

Checked against the official source on 4 Oct 2026 · Direct link

As a processor, Nexpublica developed and operated the case management software ‘Public CRM’ for the disability authority MDPH Nord. Following two data breaches in 2022, audits revealed critical vulnerabilities that had existed since 2021, such as outdated SHA-1 hashing; the French data protection authority (CNIL) imposed 1.7 million EUR directly on the service provider.

Authority / court

Commission nationale de l'informatique et des libertés (CNIL)

Area of law

Data protection · Data processors

Legal basis

Art. 32 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Checked against the official source on 25 Sep 2026 · Direct link

An employee of the customer service provider was serving two customers in chat at the same time and assigned one customer's e-mail address to the other; as a result, the complainant received the name, debts and billing data of a stranger. The Spanish data protection authority (Agencia Española de Protección de Datos, AEPD) saw the cause in the process design, which allowed parallel chats, and imposed 500,000 EUR for lack of data protection by design; the request for reconsideration was rejected.

Authority / court

Agencia Española de Protección de Datos (AEPD)

Area of law

Data protection · Data processors

Legal basis

Art. 25 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Checked against the official source on 25 Sep 2026 · Direct link

The CNIL (Commission nationale de l'informatique et des libertés, French data protection authority) fined MOBIUS SOLUTIONS LTD, a provider of tools for personalised advertising campaigns with no establishment in the EU, EUR 1,000,000: as a processor for Deezer, the company had kept a copy of the data of more than 46 million users after the contract ended, used the data without instructions to improve its own services and kept no record of its processing activities (Art. 28(3)(g), Art. 29, Art. 30 GDPR). Deezer had notified the CNIL in November 2022 that user data had appeared on the dark web.

Authority / court

Commission nationale de l'informatique et des libertés (CNIL), formation restreinte

Area of law

Data protection · Data processors

Legal basis

Art. 28 Abs. 3 lit. g, Art. 29 und Art. 30 DSGVO (Délibération SAN-2025-014 vom 11.12.2025)

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Published

19 Dec 2025

Checked against the official source on 2 Oct 2026 · Direct link

Starbucks Corporation had suppliers in Korea audited under its Ethical Sourcing Program by Elevate Hong Kong Holdings Limited, did not conclude a processing contract containing all statutory terms and did not supervise the provider adequately; Elevate processed unnecessarily large amounts of data on supplier employees, such as personnel files, wage and working-time records, and transferred them out of the businesses. The authority ordered Starbucks to award such work only under a written contract with all mandatory terms and to train and supervise the provider, and recommended data minimisation; a separate order was issued against Elevate.

Authority / court

Personal Information Protection Commission (PIPC, 개인정보보호위원회)

Area of law

Data protection · Data processors

Legal basis

Personal Information Protection Act (개인정보 보호법) Art. 26(1) und (4)

Action

Order

Status of proceedings

unknown

Sector

Food and agriculture

Employees

10,000 or more

Published

27 Nov 2025

Checked against the official source on 4 Oct 2026 · Direct link

The SaaS provider operates a system for licensed moneylenders that is linked to the Moneylenders Credit Bureau and into which its clients enter data on loan applicants and borrowers; in June 2024 an attacker used a vulnerable web application to take over the SQL server's system administrator account, which was protected only by an easily guessed password, deleted databases and exfiltrated data on 190,589 individuals including credit report data, which was offered for sale on the dark web. The Personal Data Protection Commission (PDPC, Singapore's data protection authority) found a breach of the Protection Obligation (inadequate access control, no vulnerability assessments or penetration tests) and, given the company's role as a provider processing client data entrusted to it, considered a fine of 17,500 SGD appropriate; it rejected the request for a waiver or reduction. In addition, the company must obtain the Cyber Trust mark certification of the Cyber Security Agency of Singapore (CSA) for its new network within nine months.

Authority / court

Personal Data Protection Commission (PDPC)

Area of law

Data protection · Data processors

Legal basis

Section 24(a) PDPA 2012 (Protection Obligation); Section 48J PDPA (Financial Penalty); Section 48I PDPA (Directions)

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Repeat case

no

Mitigating circumstances

Cooperation, admission under the Expedited Decision Procedure and first breach of the PDPA.

Published

3 Jul 2025

Original amount 17,500 SGD, converted at the ECB reference rate of 3 Jul 2025.

Checked against the official source on 4 Oct 2026 · Direct link

Using a customer’s identity card, an unknown person registered at least 15 prepaid numbers in her name at a Vodafone partner shop. By Decision 27/2025, the Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority) imposed on Vodafone 350,000 EUR (processing by a processor, Art. 28), 200,000 EUR (accuracy of data) and 150,000 EUR under the Greek ePrivacy law, and issued a reprimand requiring the company to secure the activation of new numbers technically within three months (for example by sending an SMS to the existing customer); the shop (partnership, anonymised) received 40,000 EUR.

Authority / court

Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority)

Area of law

Data protection · Data processors

Legal basis

Art. 5 Abs. 1 lit. d, Art. 28 Abs. 1 und 3 DSGVO; Art. 12 Gesetz 3471/2006

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

Malicious employees in partner agencies that broker contracts for Vodafone had created fictitious contracts and contract changes to the detriment of customers. The German Federal Commissioner for Data Protection and Freedom of Information (BfDI) imposed 15 million EUR for inadequate vetting and monitoring of the partner agencies (Art. 28) and 30 million EUR for authentication deficiencies in ‘MeinVodafone’ in combination with the hotline, through which unauthorised persons were able, among other things, to retrieve eSIM profiles; in addition, a reprimand was issued under Art. 32.

Authority / court

Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)

Area of law

Data protection · Data processors

Legal basis

Art. 28 Abs. 1 S. 1, Art. 32 Abs. 1 DSGVO

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Mitigating circumstances

Full cooperation including self-incrimination, modernisation of systems, separation from fraudulent partners; fines accepted and paid, plus donations amounting to millions.

Published

3 Jun 2025

Checked against the official source on 25 Sep 2026 · Direct link

The provider of point-of-sale and CRM software for small and medium-sized enterprises reported two attacks in 2024 in which perpetrators used SQL injection, among other methods, to extract files with data on a total of 698,112 individuals, including health information (skin conditions and treatments) of 9,122 individuals; the data was likely posted on a hacking forum. The Personal Data Protection Commission (PDPC, Singapore's data protection authority) stressed that the SaaS provider holds large volumes of data on behalf of its clients and found a breach of the Protection Obligation: publicly accessible servers, no network firewall, no security testing before releases, unsupported operating system and PHP versions, and credentials left unprotected in source code and configuration files. Alongside 17,500 SGD it directed a package of measures ranging from network segmentation and patch management to vulnerability assessments and penetration tests at least once a year.

Authority / court

Personal Data Protection Commission (PDPC)

Area of law

Data protection · Data processors

Legal basis

Section 24(a) PDPA 2012 (Protection Obligation)

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Repeat case

no

Mitigating circumstances

Cooperation, admission under the Expedited Decision Procedure and first breach of the PDPA.

Published

8 Jan 2026

Original amount 17,500 SGD, converted at the ECB reference rate of 7 Apr 2025.

Checked against the official source on 4 Oct 2026 · Direct link

Advanced, a processor for the NHS and care providers, was attacked with ransomware in August 2022 via a customer account without multi-factor authentication; services such as NHS 111 were disrupted. Data on 79,404 people was stolen, including instructions on how to gain entry to the homes of 890 people receiving care at home.

Authority / court

Information Commissioner's Office (ICO)

Area of law

Data protection · Data processors

Legal basis

UK GDPR Art. 32 Abs. 1 (als Auftragsverarbeiter)

Action

Fine

Status of proceedings

final

Sector

Telecoms, IT and software

Culpability

negligent

Mitigating circumstances

Provisionally £6.09 million; reduced, among other things, for proactive cooperation with the NCSC and the National Crime Agency.

Published

27 Mar 2025

Original amount 3,076,320 GBP, converted at the ECB reference rate of 26 Mar 2025.

Checked against the official source on 25 Sep 2026 · Direct link

As processor for a chiropractic practice, the IT service provider had encrypted backups without securing the key; after a ransomware attack in 2020, patient data including health information and CPR numbers could not be restored. The Danish data protection authority (Datatilsynet) reported the company to the police and proposed 50,000 DKK; the court sentenced it to a fine of 40,000 DKK on 12 November 2024.

Authority / court

Dänisches Gericht auf Anzeige der Datatilsynet

Area of law

Data protection · Data processors

Legal basis

Art. 32 DSGVO; Auftragsverarbeitungsvertrag

Action

Fine

Status of proceedings

unknown

Sector

Telecoms, IT and software

Original amount 40,000 DKK, converted at the ECB reference rate of 12 Nov 2024.

Checked against the official source on 28 Sep 2026 · Version 2 · Direct link

Following the hacker attack on an IT service provider, the Swiss Federal Data Protection and Information Commissioner (Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter, EDÖB) found that personal data of two federal offices had reached the service provider via support processes without the necessary data protection safeguards. The service provider subsequently retained the data in breach of data protection law and partly in breach of contract.

Authority / court

Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter (EDÖB)

Area of law

Data protection · Data processors

Legal basis

Datenschutzgesetz (DSG)

Action

Other

Status of proceedings

unknown

Sector

Telecoms, IT and software

Published

1 May 2024

Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 May 2026 · Direct link

The group's parent company, acting as processor, operates a shared database for several group companies; in the attack on the group's grid subsidiary, the attacker also reached customer data of other group companies because the logical separation was inadequate. As the group had not analysed the risks of joint storage or taken appropriate measures, the AEPD imposed 2,000,000 EUR (Art. 5(1)(f)) and 1,000,000 EUR (Art. 32), 3,000,000 EUR in total.

Authority / court

Agencia Española de Protección de Datos (AEPD)

Area of law

Data protection · Data processors

Legal basis

Art. 5 Abs. 1 lit. f, Art. 32 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Published

18 Apr 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 7 Feb 2026 · Direct link

A processor working for the energy supplier used data from another supplier's customer database to sign up customers by telephone while giving the impression that it was calling on behalf of their existing provider; the energy supplier only terminated the contract months later. The AEPD imposed 2,500,000 EUR each for breaching fairness and transparency (Art. 5(1)(a)) and accountability (Art. 5(2)), 5,000,000 EUR in total, and ordered a risk analysis and controls over its sales service providers; the request for reconsideration was dismissed.

Authority / court

Agencia Española de Protección de Datos (AEPD)

Area of law

Data protection · Data processors

Legal basis

Art. 5 Abs. 1 lit. a, Art. 5 Abs. 2 DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Energy and utilities

Published

18 Sep 2024

Checked against the official source on 28 Sep 2026 · Company name anonymised since 6 Feb 2026 · Direct link