Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe and North America: 718 cases from 32 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

4cases from 1 jurisdiction
€1.33mTotal of monetary amounts
€950,490Largest single case: mBank S.A.
€179,714Median per case with an amount

Click a bar to drill down one level.

When?

per quarter, by date of decision
Trend
PeriodCasesTotal
Q3 20230—
Q4 20231€23,362
Q1 20242€354,397
Q2 20240—
Q3 20241€950,490
Q4 20240—
Q1 20250—
Q2 20250—
Q3 20250—
Q4 20250—
Q1 20260—
Q2 20260—
Q3 20260—

4 cases

20 Aug 2024 mBank S.A.mBank: 4.05 million PLN for failing to inform customers after misdirected mailing PolandData breaches and data security €950,490

In 2022, an employee of a processor accidentally sent customer documents containing PESEL numbers, identity document, income and credit data to another financial institution; the envelope was returned opened. Despite a notice from the authority, the bank did not notify the data subjects because the recipient was ‘trustworthy’; Poland’s data protection authority (UODO) imposed 4,053,173 PLN and ordered the notification.

What organisations can take from it

Whether data subjects must be informed depends on the risk to them – not on how trustworthy the wrong recipient appears.

Relevance to training and awareness

Misdirected documents and notification of data subjects

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Data protection · Data breaches and data security
Legal basis
Art. 34 Abs. 1 und 2 DSGVO (DKN.5131.1.2024)
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Published
9 Sep 2024

Original amount 4,053,173 PLN, converted at the ECB reference rate of 20 Aug 2024.

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

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12 Mar 2024 Santander Bank Polska S.A.Santander Bank Polska: 1.44 million PLN – stolen customer documents not reported PolandIncident reporting obligations €336,066

A courier consignment containing bank documents (including PESEL numbers, account numbers, login credentials) was stolen and discarded on a housing estate; the supervisory authority learned of it from the media. The bank had informed neither the authority nor the data subjects because it rated the risk as low – it had already been sanctioned in 2022 for failing to notify data subjects.

What organisations can take from it

Assess the risk of a data breach from the data subjects’ perspective – failing to notify the loss of sensitive documents risks a higher penalty than the breach itself.

Relevance to training and awareness

Risk assessment and notification of data breaches

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1, Art. 34 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Employees
10,000 or more
Repeat case
yes
Published
2 Apr 2024

Original amount 1,440,549 PLN, converted at the ECB reference rate of 12 Mar 2024.

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

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12 Mar 2024 Toyota Bank Polska S.A.Toyota Bank Polska: 78,575 PLN – misdirected mailing reported only after 1.5 years PolandIncident reporting obligations €18,331

The bank sent a customer’s contract data to the wrong recipient and only reported the breach one and a half years later, when the supervisory authority made enquiries following a complaint. Given the risk of identity theft, the authority considered that there had been an obligation to notify within 72 hours.

What organisations can take from it

Even a single misdirected mailing containing identity data is notifiable – misdirected mail cases need a documented risk assessment.

Relevance to training and awareness

Recognising misdirected mail and reporting it internally

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Published
2 Apr 2024

Original amount 78,575.4 PLN, converted at the ECB reference rate of 12 Mar 2024.

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

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18 Oct 2023 Link4 Towarzystwo Ubezpieczeń S.A.Link4: 103,752 PLN – misdirected e-mail not reported after using a risk calculator PolandIncident reporting obligations €23,362

The insurer sent a claims settlement confirmation containing name, address, vehicle and claim data by e-mail to an unauthorised person. After an assessment using an online calculator, it rated the risk as low and did not notify; the supervisory authority found that the notification obligation had been breached and treated, among other things, intent and lack of cooperation as aggravating factors.

What organisations can take from it

Risk assessment tools do not replace judgement – anyone sending out information covered by insurance secrecy should notify if in doubt.

Relevance to training and awareness

Avoiding misdirected e-mails; reporting data breaches

Authority / court
Prezes Urzędu Ochrony Danych Osobowych (UODO)
Area of law
Information security and cyber · Incident reporting obligations
Legal basis
Art. 33 Abs. 1 DSGVO
Action
Fine
Status of proceedings
unknown
Sector
Financial services and insurance
Culpability
intentional
Repeat case
yes
Published
23 Nov 2023

Original amount 103,752 PLN, converted at the ECB reference rate of 18 Oct 2023.

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

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