Who was sanctioned, and for what?

Hospital staff opened a colleague's electronic health record to organise duty rosters during Covid rather than for treatment purposes. Technical barriers limiting access to treating staff were lacking; the Italian data protection authority (Garante per la protezione dei dati personali) imposed 24,000 EUR (Provvedimento No. 616).

Authority / court

Garante per la protezione dei dati personali

Area of law

Data protection · Employee data

Legal basis

Art. 5 Abs. 1 lit. a, b, c, f, Art. 9, 25, 32 DSGVO; Art. 75 Codice privacy; Linee guida dossier sanitario

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Published

11 Sep 2026

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

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In summer 2025, an attacker gained access to the private hospital's electronic patient record system and obtained data on 524,867 patients and 202,246 trusted persons. There was no VPN or multi-factor authentication for external users, no appropriate access control and no detection of suspicious activity; the trusted persons were not notified. France's data protection authority (Commission nationale de l'informatique et des libertés, CNIL) imposed a fine of 500,000 EUR (SAN-2026-009).

Authority / court

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

Area of law

Data protection · Data breaches and data security

Legal basis

DSGVO Art. 32, Art. 34

Action

Fine

Status of proceedings

final

Sector

Healthcare

Published

3 Sep 2026

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

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From May to the end of August 2024, the public hospital accidentally published on its website a surgery list containing patients' telephone numbers, illnesses and planned procedures; a member of the public found the document via Google. The Hellenic Data Protection Authority imposed a total of 25,000 EUR: 10,000 EUR for inadequate security, 2,000 EUR for the late notification, 10,000 EUR for failing to notify the data subjects and 3,000 EUR for missing contact details of the data protection officer (DPO).

Authority / court

Αρχή Προστασίας Δεδομένων Προσωπικού Χαρακτήρα (Hellenic Data Protection Authority)

Area of law

Data protection · Data breaches and data security

Legal basis

DSGVO Art. 5 Abs. 1 lit. f, 32 Abs. 1, 33 Abs. 1, 34 Abs. 1, 12, 13 i. V. m. 37 (Entscheidung 13/2026)

Action

Fine

Status of proceedings

final

Sector

Healthcare

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

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On application by its competitor Ramus, the Комисия за защита на конкуренцията (Bulgarian Commission for the Protection of Competition, KZK) established that the laboratory had offered packages of medical laboratory tests free of charge nationwide over extended periods (only against a fee of 2 leva for taking blood) – conduct shown by no other market participant outside joint campaigns. It found an infringement of the general clause of unfair competition law (Art. 29 ZZK – Bulgarian Protection of Competition Act) and imposed 0.3% of 2024 turnover, i.e. 52,096.55 EUR. Appeals have been lodged against the decision.

Authority / court

Комисия за защита на конкуренцията (КЗК, Bulgarische Wettbewerbskommission)

Area of law

Competition law

Legal basis

Art. 29 ZZK (Generalklausel unlauterer Wettbewerb)

Action

Fine

Status of proceedings

under appeal

Sector

Healthcare

Published

2 Jul 2026

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

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Four laboratories and their association coordinated negotiations on prices with health insurers, coordinated in tenders, exchanged sensitive information and allocated customers. At first instance, the Protimonopolný úrad Slovenskej republiky (Antimonopoly Office of the Slovak Republic, PMÚ SR) imposed 14,551,800 EUR and three-year procurement bans; Unilabs received a substantially reduced fine as leniency applicant and under a settlement.

Authority / court

Protimonopolný úrad Slovenskej republiky (PMÚ SR)

Area of law

Competition law · Cartels and collusion

Legal basis

Slowakisches Wettbewerbsschutzgesetz (Kartellverbot)

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Culpability

intentional

Mitigating circumstances

Unilabs: leniency reduction (50%) and settlement (a further 30%).

Published

12 May 2026

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

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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 25 Sep 2026 · Direct link

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A general practitioner who had no longer been treating the complainant since January 2023 accessed his health data (findings, prescriptions) on the national e-health platform EESZT a total of 47 times via his practice software until August 2024 and did not respond to an access request. The Hungarian data protection authority (Nemzeti Adatvédelmi és Információszabadság Hatóság, NAIH) found infringements of Art. 5(2), 6(1), 9(2), 12(2) and 15(1) GDPR, ordered compliance with the access request and imposed 500,000 HUF.

Authority / court

Nemzeti Adatvédelmi és Információszabadság Hatóság (NAIH)

Area of law

Data protection · Data subject rights and transparency

Legal basis

DSGVO Art. 5 Abs. 2, 6 Abs. 1, 9 Abs. 2, 12 Abs. 2, 15 Abs. 1 (NAIH-273-7/2026)

Action

Fine

Status of proceedings

final

Sector

Healthcare

Published

20 Mar 2026

Original amount 500,000 HUF, converted at the ECB reference rate of 20 Mar 2026.

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

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In parallel with the US declination, the PNF concluded a CJIP with the US subsidiary of the French medical technology manufacturer for 1,765,493 EUR (after crediting the US disgorgement) and a three-year AFA compliance programme. The case arose from Balt SAS's voluntary self-disclosure of 22 May 2023 concerning offences committed by a former manager of the acquired company Blockade Medical.

Authority / court

Parquet national financier (PNF); Validierung durch den Präsidenten des Tribunal judiciaire de Paris

Area of law

Bribery and corruption · Bribery of public officials

Legal basis

Art. 41-1-2 Code de procédure pénale (CJIP); aktive und passive Bestechung von Amtsträgern

Action

Fine

Status of proceedings

final

Sector

Healthcare

Employees

250 to 999

Culpability

intentional

Mitigating circumstances

Voluntary self-disclosure to the PNF and the DOJ; coordinated resolution with crediting.

Liability of senior managers

The CJIP does not address the criminal liability of natural persons.

Published

19 Mar 2026

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

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The clinic’s managing director himself reported that a former employee had copied contact details and patient records of all patients and poached them for a new clinic. In the subsequent investigation, the clinic did not fully answer the requests of the Romanian data protection authority (ANSPDCP) despite a reprimand and an order; the authority therefore imposed 10,190 lei (2,000 EUR). Date = publication of the press release; according to the authority, the investigation was concluded in February 2026.

Authority / court

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

Area of law

Data protection

Legal basis

Art. 58 Abs. 1, Art. 83 Abs. 5 lit. e DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Published

20 Feb 2026

Original amount 10,190 RON, converted at the ECB reference rate of 20 Feb 2026.

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

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The Bezirkshauptmannschaft (district administrative authority) penalised the managing director of a Tyrolean hospital operator because in September 2022 physicians had not been granted sufficient rest periods after extended shifts and maximum duty hours had been exceeded; the Regional Administrative Court set aside several counts because the time clock data were said to have been incorrect. On an official appeal on points of law (Amtsrevision) by the Minister of Labour, the Verwaltungsgerichtshof (Austrian Supreme Administrative Court, VwGH) partly set aside that ruling: witness statements alone are not sufficient to rebut time clock records.

Authority / court

Verwaltungsgerichtshof (VwGH); Strafbehörde: Bezirkshauptmannschaft Innsbruck

Area of law

Health and safety and employment law · Working time

Legal basis

§§ 4 Abs. 4 Z 1, 7 Abs. 3, 11 Abs. 1, 12 Abs. 1 Krankenanstalten-Arbeitszeitgesetz (KA-AZG); § 9 VStG

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Liability of senior managers

Fines imposed on the managing director under commercial law; liability of the company under § 9(7) VStG.

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

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The two companies colluded in tenders of the General Health Insurance Company for the supply of medicines (2017–2020). For the first time, a cartel was uncovered on the basis of information from a whistleblower; the Protimonopolný úrad Slovenskej republiky (Antimonopoly Office of the Slovak Republic, PMÚ SR) imposed 7,595,200 EUR and a one-year procurement ban on PHOENIX and 201,800 EUR and a three-year procurement ban on TRANSMEDIC (first instance).

Authority / court

Protimonopolný úrad Slovenskej republiky (PMÚ SR)

Area of law

Competition law · Cartels and collusion

Legal basis

Slowakisches Wettbewerbsschutzgesetz (Submissionsabsprache)

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

Culpability

intentional

Mitigating circumstances

PHOENIX: settlement with a 30% fine reduction and a shortened procurement ban.

Published

24 Feb 2026

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

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Doctolib tied doctors with exclusivity clauses, bundled telemedicine with the appointment booking subscription and in 2018 acquired its main competitor MonDocteur in order to eliminate it (decision 25-D-06). Fines: 4.615 million EUR for exclusivity and tying, 50,000 EUR for the acquisition.

Authority / court

Autorité de la concurrence

Area of law

Competition law · Abuse of market power

Legal basis

Art. 102 AEUV, Art. L.420-2 Code de commerce

Action

Fine

Status of proceedings

under appeal

Sector

Healthcare

Culpability

intentional

Published

6 Nov 2025

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

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Despite access requests, two patients did not receive copies of their scan files at the end of treatment; the practice responded only sluggishly to enquiries and did not attend an appointment with the supervisory authority. The Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate, AKI) ordered disclosure under Art. 15(3) GDPR or a reasoned refusal and threatened a penalty payment of 2,000 EUR.

Authority / court

Andmekaitse Inspektsioon (AKI)

Area of law

Data protection · Data subject rights and transparency

Legal basis

§ 56 Abs. 1 IKS; Art. 58 Abs. 2 lit. c, Art. 12 Abs. 4, Art. 15 DSGVO

Action

Order

Status of proceedings

unknown

Sector

Healthcare

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

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For almost six years, the chair of the management board of the medical company was also its data protection officer; this came to light after a report that a patient had been handed documents relating to another person. Poland’s data protection authority (UODO) found a conflict of interest and imposed 11,365 PLN.

Authority / court

Prezes Urzędu Ochrony Danych Osobowych (UODO)

Area of law

Data protection

Legal basis

Art. 38 Abs. 6 DSGVO (DKN.5131.7.2025)

Action

Fine

Status of proceedings

final

Sector

Healthcare

Mitigating circumstances

An independent external data protection officer was appointed in July 2024.

Published

29 Sep 2025

Original amount 11,365 PLN, converted at the ECB reference rate of 12 Sep 2025.

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

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On 1 August 2024, a doctor accessed e-prescriptions and medication data of a former employee twelve times in the ELGA electronic health record without any treatment relationship. The Austrian Data Protection Authority (Datenschutzbehörde, DSB) imposed 1,000 EUR (plus 100 EUR in costs); confession and a clean record were mitigating factors.

Authority / court

Datenschutzbehörde

Area of law

Data protection · Employee data

Legal basis

DSGVO Art. 5 Abs. 1 lit. a und b, Art. 6 Abs. 1, Art. 9 Abs. 1 und 2

Action

Fine

Status of proceedings

final

Sector

Healthcare

Culpability

negligent

Mitigating circumstances

No previous record, negligence, full cooperation and confession.

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

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A practice for aesthetic treatments advertised hyaluronic acid filler injections for the nose and chin on its website and on Instagram using before-and-after images. In an action brought by a consumer advice centre (Verbraucherzentrale), the BGH upheld the injunction issued by the Higher Regional Court of Hamm (OLG Hamm): such procedures are deemed to be surgical cosmetic procedures, for which this kind of advertising is prohibited.

Authority / court

Bundesgerichtshof (I. Zivilsenat), Az. I ZR 170/24

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

§ 11 Abs. 1 Satz 3 Nr. 1, § 1 Abs. 1 Nr. 2 Buchst. c HWG; UKlaG

Action

Order

Status of proceedings

final

Sector

Healthcare

Published

31 Jul 2025

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

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In 2018–2022, the online pharmacy transmitted purchase data, including data on prescription medicines, to the tracking providers via Google and Meta tracking. The sanctions board of the Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman) imposed 1.1 million EUR and a reprimand; on 1 June 2026 the Helsingin hallinto-oikeus (Helsinki Administrative Court) upheld the infringement but annulled the fine because it was unclear whether a fine may be imposed on the university pharmacy at all (not final).

Authority / court

Tietosuojavaltuutetun toimisto – seuraamuskollegio; Helsingin hallinto-oikeus

Area of law

Data protection · Cookies and tracking

Legal basis

DSGVO Art. 9, Art. 25, Art. 32

Action

Fine

Status of proceedings

overturned

Sector

Healthcare

Published

4 Jun 2025

Amount in EUR; no ECB reference rate is available for this currency.

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

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Despite being asked to do so, a healthcare provider (name redacted) did not correct a patient’s address, so that health reports were sent to third parties, and used address data from the electoral register without a legal basis. The Information and Data Protection Commissioner (IDPC) issued a reprimand, ordered rectification, erasure of the register data and the designation of a data protection officer, and imposed fines of 12,500, 5,000 and 2,500 EUR.

Authority / court

Information and Data Protection Commissioner (IDPC)

Area of law

Data protection · Data subject rights and transparency

Legal basis

Art. 5 Abs. 1 lit. a und d, Art. 6 Abs. 1, Art. 14, 16, 37 Abs. 1 lit. c DSGVO

Action

Fine

Status of proceedings

unknown

Sector

Healthcare

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

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Following a tip-off from the Military Medical Academy (VMA), the Комисия за защита на конкуренцията (Bulgarian Commission for the Protection of Competition, KZK) found that the centre presented its gynaecological practice as a VMA branch with signs reading ‘МЦ „ЛЮЛИН МЕД“ АГ – ВМА ФИЛИАЛ’ and corresponding online information. For misleading conduct (Art. 31 ZZK – Bulgarian Protection of Competition Act) it imposed 0.4% of 2023 turnover, i.e. 9,236 leva. An appeal has been lodged against the decision.

Authority / court

Комисия за защита на конкуренцията (КЗК, Bulgarische Wettbewerbskommission)

Area of law

Consumer protection and online retail · Misleading advertising and pricing

Legal basis

Art. 31 ZZK (Irreführung)

Action

Fine

Status of proceedings

under appeal

Sector

Healthcare

Original amount 9,236 BGN, converted at the ECB reference rate of 6 Feb 2025.

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

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A limited company operating a diagnostic laboratory (name pseudonymised), which during the pandemic carried out up to 45,000 PCR analyses a day with around 200 employees, had appointed its managing director as data protection officer at the same time. Because of the resulting conflict of interest, the Austrian data protection authority (Datenschutzbehörde, DSB) imposed 5,000 EUR; the penalty decision is final.

Authority / court

Datenschutzbehörde (DSB)

Area of law

Data protection

Legal basis

Art. 37, Art. 38 Abs. 6 DSGVO

Action

Fine

Status of proceedings

final

Sector

Healthcare

Employees

50 to 249

Liability of senior managers

The managing director was also appointed as data protection officer – an impermissible conflict of interest.

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

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