Compliance Radar
Who was sanctioned, and for what?
Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific, Middle East and Africa: 2,207 cases from 44 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.
Click a bar to drill down one level.
Where?
by regionAll jurisdictions
What for?
by area of lawAll areas of law
- Bribery and corruption €246.2m 44 % · 18 cases
- Capital markets and financial supervision €167m 30 % · 3 cases
- Competition law €119.5m 21 % · 14 cases
- Data protection €26.3m 5 % · 45 cases
- Health and safety and employment law €1.78m 0 % · 5 cases
- Sanctions and export control €1.47m 0 % · 1 case
- Information security and cyber €1.38m 0 % · 1 case
- Whistleblower protection €1.26m 0 % · 1 case
- Consumer protection and online retail €133,279 0 % · 4 cases
- AI and digital regulation – 0 % · 1 case
Who?
by company- Anonymised companies €221.6m 39 % · 45 cases
- Becton, Dickinson and Company (BD) €166.7m 30 % · 1 case
- Access DX Laboratory, LLC €31.7m 6 % · 1 case
- Advanced Pathology Solutions PLLC und APS MSO LLC €25.9m 5 % · 1 case
- C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical Corporation €16.3m 3 % · 1 case
- NUWAY Alliance, Inc. €15.8m 3 % · 1 case
- Medirex s. r. o.; KLINICKÁ BIOCHÉMIA s.r.o.; Unilabs Slovensko, s. r. o.; synlab slovakia s. r. o.; Asociácia laboratórií €14.6m 3 % · 1 case
- Oroville Hospital €9.77m 2 % · 1 case
- NeoGenomics Laboratories Inc. €8.59m 2 % · 1 case
- PHOENIX Zdravotnícke zásobovanie, a.s.; TRANSMEDIC SLOVAKIA, s.r.o. (in Konkurs) €7.8m 1 % · 1 case
- 35 more€46.1m
When?
per year, by date of decision| Period | Cases | Total |
|---|---|---|
| 2022 | 5 | €88.6m |
| 2023 | 23 | €74.5m |
| 2024 | 23 | €235.2m |
| 2025 | 18 | €59.6m |
| 2026 | 24 | €107.1m |
93 cases
3 Sep 2026 Azienda Sanitaria Universitaria Friuli Centrale (ASUFC)Garante: Udine hospital group pays 24,000 EUR for viewing a colleague's patient record €24,000
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).
Patient records may only be opened for treatment – include this in training and secure it technically through role-based rights and logging.
Purpose limitation when accessing patient records
- 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
- Newsletter del 11 settembre 2026 – Garante privacy Press release of an authority
- Garante privacy, azienda sanitaria di Udine sanzionata per 24mila euro Press release of an authority
- Garante – Provvedimento n. 616 del 3 settembre 2026 [10293994] (ASUFC) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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14 Aug 2026 Plexon, Inc.Plexon: brain research recording systems to listed Chinese military medical academy – 1.7 million USD suspended €1.47m
The neurotechnology company from Dallas, described by the Bureau of Industry and Security (BIS, the export control agency of the US Department of Commerce) as small, delivered neural data acquisition systems (“OmniPlex”) and accessories worth around 179,000 USD on eight occasions in 2022/23 via its Asian distributor to the Chinese Academy of Military Medical Sciences, which has been on the Entity List (the US export control list of restricted parties) since December 2021. The penalty of 1.7 million USD is suspended for five years and then waived, provided that Plexon submits an external audit of its export compliance programme on time and commits no further violations; a five-year denial of export privileges is likewise suspended, and Plexon must also provide export control training.
Screen orders placed via distributors against the Entity List before production – research equipment can also end up with listed military institutions.
Entity List screening for orders via distribution partners
Missing or inadequate training played a role in the decision.
- Authority / court
- U.S. Department of Commerce, Bureau of Industry and Security (BIS)
- Area of law
- Sanctions and export control · Export control and dual-use goods
- Legal basis
- Export Administration Regulations, 15 C.F.R. § 764.2(a), § 744.11
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Penalty and denial of export privileges fully suspended for five years, conditional on an external export control audit.
- Published
- 14 Aug 2026
Original amount 1,700,000 USD, converted at the ECB reference rate of 14 Aug 2026.
- BIS Reaches Administrative Enforcement Settlement with Plexon, Inc. Press release of an authority
- Order Relating to Plexon, Inc., Settlement Agreement und Proposed Charging Letter Decision of an authority
Checked against the official source on 28 Sep 2026 · Direct link
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30 Jul 2026 Access DX Laboratory, LLCAccess DX Laboratory: 36.4 million USD – kickbacks for unnecessary genetic tests €31.7m
The Houston laboratory allegedly paid kickbacks and billed Medicare and Medicaid for medically unnecessary genetic tests. The settlements with the laboratory and other parties add up to 36.4 million USD (combined total); the laboratory is subject to a Corporate Integrity Agreement.
Commission models for intermediaries who bring in orders or patients are a classic gateway for bribery.
Remuneration of intermediaries and referrers
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Measures against individuals are not reported here.
Original amount 36,400,000 USD, converted at the ECB reference rate of 30 Jul 2026.
- HHS-OIG Enforcement Actions: Vergleiche mit Access DX Laboratory und weiteren Beteiligten (30.07.2026) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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21 Jul 2026 Hôpital Privé de la LoireHôpital Privé de la Loire: 500,000 EUR after data exfiltration affecting over 520,000 patients €500,000
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).
External access to patient records belongs behind multi-factor authentication and continuous monitoring for unusual access.
Access security and attack detection in hospitals
- 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
- Sanction : amende de 500 000 euros à l'encontre de l'Hôpital Privé de la Loire Press release of an authority
- Délibération SAN-2026-009 du 21 juillet 2026 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jul 2026 NeoGenomics Laboratories Inc.NeoGenomics: 9.8 million USD after self-disclosure – discounted consulting for referring physicians €8.59m
The Florida laboratory provided referring physicians with consulting services below market value and paid independent consultants referral-based remuneration for recruiting physicians. Following a self-disclosure, NeoGenomics paid 9,813,260 USD.
Free or discounted services are also benefits – like cash payments, they belong in the anti-corruption review.
Services with monetary value provided to customers below market value
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Self-disclosure of the remuneration arrangements.
Original amount 9,813,260 USD, converted at the ECB reference rate of 20 Jul 2026.
- HHS-OIG Enforcement Actions: Florida Laboratory Agrees to Pay $9.8M … Self-Disclosure of Compensation Arrangements (20.07.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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7 Jul 2026 Γενικό Νοσοκομείο Θεσσαλονίκης Γ. Γεννηματάς «Ο Άγιος Δημήτριος» (Allgemeines Krankenhaus Thessaloniki G. Gennimatas – Agios Dimitrios)Thessaloniki hospital: 25,000 EUR because surgery lists with diagnoses were online €25,000
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).
Every publication on the website needs an approval step that reliably intercepts documents containing health data – and after a data breach, data subjects must be informed.
Publication of documents containing health data
- 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
- Επιβολή προστίμου σε νοσοκομείο (Απόφαση 13/2026) Decision of an authority
- Απόφαση 13/2026 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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25 Jun 2026 Самостоятелна медико-диагностична лаборатория „Лина“ ЕООДLaboratory Lina lures customers with free blood tests – 52,097 EUR for unfair competition €52,097
On application by a competitor, 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.
Permanent free offers to win customers can be unfair if they deviate significantly from market practice and drive out competitors.
- 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
- КЗК Публичен електронен регистър – Производство (Решение № 591 от 25.06.2026; Volltext als PDF im Register) Official register or notice
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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18 Jun 2026 St. Joseph's Healthcare HamiltonHamilton hospital: CA$65,000 after injury caused by known centrifuge defect €40,151
In the teaching hospital's virology laboratory, the lid of a centrifuge fell on an employee who had to hold it open by hand because of a defective gas spring; she was seriously injured. Maintenance reports from 2023 and 2024 had already called for the spring to be replaced. Fine of CA$65,000 plus victim fine surcharge.
A defect documented in maintenance reports that is not remedied makes every subsequent accident foreseeable – defective equipment must be taken out of use.
Reporting defective equipment and taking it out of service
- Authority / court
- Provincial Offences Court Hamilton (Ermittlung: Ontario Ministry of Labour, Immigration, Training and Skills Development)
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Section 25(1)(b) Occupational Health and Safety Act (Ontario)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Guilty plea; repair two days after the accident.
- Published
- 21 Jul 2026
Original amount 65,000 CAD, converted at the ECB reference rate of 18 Jun 2026.
- St. Joseph's Healthcare Hamilton Fined $65,000 for Workplace Injury (Ontario Newsroom, Court Bulletin) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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17 Jun 2026 Advanced Pathology Solutions PLLC und APS MSO LLCAdvanced Pathology Solutions: 30 million USD for kickbacks and unnecessary laboratory tests €25.9m
The Arkansas pathology laboratory and its management company allegedly granted unlawful kickbacks and ordered medically unnecessary tests. The settlement of 30 million USD is a joint payment by all settling parties; the laboratory entered into a Corporate Integrity Agreement.
Where services are sold through referrals, all benefits to referrers belong in a central approval and review procedure.
Benefits to clients in healthcare
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Measures against individuals are not reported here.
Original amount 30,000,000 USD, converted at the ECB reference rate of 17 Jun 2026.
- HHS-OIG Enforcement Actions: Vergleich mit Advanced Pathology Solutions (17.06.2026) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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11 Jun 2026 Monash IVF Pty LtdMonash IVF: tracking pixels on fertility website used without consent Order
Monash IVF collected sensitive information about visitors to its fertility treatment website through third-party tracking pixels. The Privacy Commissioner held that following the visitors of health-related websites and afterwards showing them targeted adverts on social networks amounts to collecting sensitive data, which requires consent, and found breaches of APP 3.3, 5.1, 5.2 and 7.1. Monash IVF must not continue or repeat the conduct and must implement specified remedial steps; a parallel determination against the telehealth provider Medmate Australia was made on the same day.
Anyone using tracking pixels on health websites needs visitors' consent and must know which data flows to advertising platforms.
Tracking pixels and advertising tools on websites with sensitive content
- Authority / court
- Office of the Australian Information Commissioner (OAIC)
- Area of law
- Data protection · Cookies and tracking
- Legal basis
- Privacy Act 1988 (Cth), APP 3.3, 5.1, 5.2, 7.1
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 24 Jun 2026
- OAIC: Privacy Commissioner finds privacy breaches in third-party tracking pixel investigation (24.06.2026) Press release of an authority
- OAIC: Privacy determinations – Commissioner Initiated Investigation into Monash IVF Pty Ltd (Privacy) [2026] AICmr 40 (11 June 2026) Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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10 Jun 2026 Health Service Executive (HSE)DPC: €300,000 fine against HSE after ransomware attack on hospital laboratory in Tullamore €300,000
In November 2018 attackers encrypted patient data in the laboratory information system of Midlands Regional Hospital Tullamore. The DPC found that the HSE had infringed Art. 5(1)(f), 28, 30, 32(1) and 34 GDPR (including insufficient security, deficient processor contracts and record of processing, and incomplete notification of affected persons), issued a reprimand, imposed €300,000 for the security failings (Art. 5(1)(f) and 32(1)) and ordered it to introduce specified policies and procedures for secure processing.
Laboratory and other specialist hospital systems also belong in security and supplier management; contracts with processors must contain the GDPR safeguards.
Ransomware protection of clinical systems
- Authority / court
- Data Protection Commission (DPC)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Art. 5(1)(f), 28, 30, 32(1), 34 DSGVO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- DPC: Inquiry into Midlands Regional Hospital Tullamore (IN-19-9-4) Decision of an authority
Checked against the official source on 2 Oct 2026 · Direct link
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2 Jun 2026 Ascension Health Alliance; AmSurg LLC / Ambulatory Topco LLCAscension/AmSurg: seven ambulatory surgery centres must be sold Order
The non-profit hospital group Ascension wanted to acquire AmSurg for 3.9 billion USD. Owing to overlaps in outpatient surgery in five regions, the Federal Trade Commission (FTC) requires the sale of seven AmSurg centres to SC Affiliates and a gastroenterology practice, as well as transitional support.
Non-profit healthcare providers are also subject to merger control – regional market shares determine divestitures.
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Competition law · Merger control
- Legal basis
- Section 7 Clayton Act; Section 5 FTC Act (Consent Order)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Healthcare
- Employees
- 10,000 or more
- FTC Requires Divestiture of Ambulatory Surgery Centers … Ascension Health-AmSurg Deal (02.06.2026) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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26 May 2026 IQVIA Operations FranceCNIL: €5m fine for IQVIA Operations France over health data warehouses €5m
The CNIL (French data protection authority) fined IQVIA Operations France EUR 5,000,000 because, for two health data warehouses authorised by the CNIL (fed with data from around 14,000 pharmacies and several thousand medical practices), the company did not comply with the conditions of the authorisations, including log analysis, multi-factor authentication, patient information and the right to object. In addition, pharmacy customers were not informed of the transfer of their data, in-house studies were carried out without the required authorisation and the pharmacy software transmitted data even after a refusal (Art. 25 GDPR). The CNIL classified the data as pseudonymised rather than anonymous and ordered remedial action within six months, subject to a penalty payment of EUR 10,000 per day.
Anyone working with authorised health data must implement the conditions of the authorisation technically as well and actively monitor how partners inform the individuals concerned.
Conditions for processing health data
- Authority / court
- Commission nationale de l'informatique et des libertés (CNIL), formation restreinte
- Area of law
- Data protection · Data subject rights and transparency
- Legal basis
- Art. 66 Loi n° 78-17 du 6 janvier 1978 (Loi Informatique et Libertés); Art. 14 und 25 DSGVO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Culpability
- negligent
- Mitigating circumstances
- The security shortcomings were remedied after the inspections.
- Published
- 28 May 2026
- CNIL: Données de santé : sanction de 5 millions d'euros à l'encontre de la société IQVIA (28.05.2026) Press release of an authority
- Délibération de la formation restreinte n° SAN-2026-008 du 26 mai 2026 concernant la société IQVIA OPERATIONS FRANCE Decision of an authority
Checked against the official source on 2 Oct 2026 · Direct link
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1 May 2026 Modern Nuclear Inc.Modern Nuclear: 8.33 million USD – excessive supervision fees paid to referring cardiologists €7.12m
The Californian provider of mobile PET scans allegedly paid referring cardiologists excessive fees for supervising the examinations in order to secure referrals. The settlement of 8,334,350.71 USD plus revenue-based payments is based on ability to pay; in addition, there is a Corporate Integrity Agreement.
Remuneration of business partners who refer work must correspond to the market value of the service – any overpayment acts as a bribe.
Checking fee agreements with referrers for market conformity
- Authority / court
- U.S. Department of Justice / U.S. Attorney's Office, Central District of California
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 8,334,350.71 USD, converted at the ECB reference rate of 30 Apr 2026.
- HHS-OIG Enforcement Actions: Mobile PET Scan Provider to Pay $8.33 Million … Unlawful Kickbacks to Medical Practices (01.05.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 May 2026 LiveBetter Services LimitedLiveBetter Services: 675,000 AUD after fatal scalding of an NDIS participant €412,314
Following an investigation by SafeWork NSW, the District Court of NSW fined LiveBetter Services Limited 675,000 AUD for a breach of ss 32/19(2) of the Work Health and Safety Act 2011. In February 2022, a participant in the National Disability Insurance Scheme (NDIS) was placed in a bath with excessively hot water, suffered serious burns and died from her injuries.
When bathing people in care, water temperature must be limited by technical means and checked before every bath.
Preventing scalds in care and support services
- Authority / court
- SafeWork NSW
- Area of law
- Health and safety and employment law · Workplace safety and accidents
- Legal basis
- Work Health and Safety Act 2011 (NSW) ss 32/19(2)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
Original amount 675,000 AUD, converted at the ECB reference rate of 30 Apr 2026.
- SafeWork NSW: Prosecution summaries – May 2026 (LiveBetter Services Limited, 1 May 2026) Enforcement database of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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17 Apr 2026 Medirex s. r. o.; KLINICKÁ BIOCHÉMIA s.r.o.; Unilabs Slovensko, s. r. o.; synlab slovakia s. r. o.; Asociácia laboratóriíLaboratory cartel: 14.6 million EUR and procurement bans against diagnostic laboratories €14.6m
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.
Common negotiating positions towards payers via an association are a cartel – association meetings need minutes and a review of the agenda.
Information exchange among competitors and association work
- 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
- KARTELY: PMÚ odhalil kartel laboratórií a uložil pokuty takmer 15 miliónov eur Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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16 Apr 2026 Fullgevity OÜ (vormals Zahnarztpraxis unter Inhabernamen, anonymisiert)Fullgevity (dental clinic) must reorganise data processing in Invisalign treatment Order
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.
Anyone passing patient data on to manufacturers or platforms must clarify roles, contracts and consents properly in advance – and respond to supervisory requests on time.
Consent and transparency for health data; cooperation with the supervisory authority
- 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
- Ettekirjutus-hoiatus isikuandmete kaitse asjas nr 2.1-1/24/397-890-38 (Fullgevity OÜ), 16.04.2026 Decision of an authority
- Andmekaitse Inspektsioon – veröffentlichte Ettekirjutused (Liste) Official register or notice
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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20 Mar 2026 Gesundheitsdienstleister (in der Entscheidung anonymisiert)Hungarian GP practice: 500,000 HUF for 47 EESZT queries without legal basis €1,274
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.
Every access to electronic health records is logged and must be linked to treatment – even if it is triggered by practice staff.
Access to health data and access requests
- 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
- 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.
- NAIH-273-7/2026 – Jogalap nélküli hozzáférés az EESZT rendszeréhez Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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19 Mar 2026 Balt USA LLC (Balt-Gruppe)Balt USA: CJIP in France over payments to a hospital physician €1.77m
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 conduct at the acquired company Blockade Medical.
Acquisitions require anti-corruption due diligence on the target company – otherwise legacy misconduct by its management becomes a group risk.
Benefits to hospital physicians, integration of acquired companies
- 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
- Communiqué de presse du procureur de la République financier – CJIP BALT USA Press release of an authority
- Ministère de la Justice – Conventions judiciaires d'intérêt public (Liste) Official register or notice
- CJIP Société BALT USA LLC (17.03.2026) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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17 Mar 2026 Balt SAS / Balt USA LLCMedical technology: DOJ declination for Balt SAS after bribery of a hospital physician €1.05m
Through sham consultancy agreements, fictitious invoices and purported bonus payments, around 602,000 USD in bribes flowed from 2017 to 2023 via a Belgian consultant to a physician in a senior position at a French public hospital, so that the hospital would purchase embolisation coils from Balt. The DOJ declined to prosecute on account of voluntary self-disclosure, cooperation and remediation (declination of 17 March 2026); Balt is disgorging 1,214,797 USD in profits.
Physicians at public hospitals are public officials – consultancy agreements with them require documented services and approval by the compliance function.
Benefits to physicians in the public healthcare sector, sham consultancy agreements
- Authority / court
- U.S. Department of Justice (Criminal Division, Fraud Section)
- Area of law
- Bribery and corruption · Bribery of public officials
- Legal basis
- FCPA; Corporate Enforcement and Voluntary Self-Disclosure Policy (Declination)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- intentional
- Mitigating circumstances
- Voluntary self-disclosure (including to the French national financial prosecutor's office, PNF), full cooperation, timely remediation, disciplinary measures, parallel resolution in France.
- Liability of senior managers
- Measures against individuals are not reported here.
- Published
- 19 Mar 2026
Original amount 1,214,797 USD, converted at the ECB reference rate of 17 Mar 2026.
- U.S. Department of Justice, Pressemitteilung zu Balt SAS (Entscheidung 2026) Press release of an authority
- Communiqué de presse du procureur de la République financier – CJIP BALT USA (19.03.2026) Press release of an authority
- DOJ Criminal Division, Fraud Section: Declination Letter Re: Balt SAS (17.03.2026) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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5 Mar 2026 Allin IP DX LLCAllin IP DX: 980,000 USD after self-disclosure over paid referral marketers €843,519
Between January and June 2023, the Sarasota laboratory paid independent marketers to steer laboratory samples from Medicare beneficiaries to it. It self-disclosed the conduct, cooperated extensively and paid 980,000 USD.
Early self-disclosure limits the damage – but this requires the compliance function to actually get to see problematic sales contracts.
Success-based remuneration of sales partners
- Authority / court
- U.S. Attorney's Office, Middle District of Florida
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Voluntary self-disclosure, detailed disclosure and cooperation.
Original amount 980,000 USD, converted at the ECB reference rate of 5 Mar 2026.
- HHS-OIG Enforcement Actions: Sarasota Lab Agrees to Pay $980,000 to Resolve False Claims Act Violations (05.03.2026) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Feb 2026 SC Hayat Dent SRLDental clinic Hayat Dent obstructs investigation of data leak – 2,000 EUR €1,999
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.
Offboarding processes must block data access immediately – and anyone reporting an incident must also support its investigation.
Taking patient data when leaving; cooperation with the supervisory authority
- 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.
- ANSPDCP – Comunicat de presă 20.02.2026 (SC Hayat Dent SRL) Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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18 Feb 2026 Fraser Health Authority, Provincial Health Services Authority, Vancouver Coastal HealthBritish Columbia: 36 hospital staff accessed records of Lapu-Lapu Day victims without authorisation Other
Following the tragedy at the Lapu-Lapu Day festival in 2025, 36 employees of three health authorities accessed patient data of 16 admitted persons without authorisation in 71 instances. Those affected were not informed without undue delay; the Information and Privacy Commissioner for British Columbia (OIPC BC) made nine recommendations, including automated access monitoring and deterrent disciplinary measures.
Curiosity is no reason for access: monitor access to the records of high-profile cases in real time and sanction breaches noticeably.
Unauthorised viewing of patient records (snooping)
- Authority / court
- Office of the Information and Privacy Commissioner for British Columbia (OIPC BC)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Freedom of Information and Protection of Privacy Act (FIPPA) BC, s. 25.1
- Action
- Other
- Status of proceedings
- unknown
- Sector
- Healthcare
- Culpability
- intentional
- Mitigating circumstances
- Appropriate safeguards were in place; the authorities responded quickly and accepted all recommendations.
- Published
- 18 Feb 2026
- Investigation reveals 71 snooping incidents by 36 healthcare workers following Lapu Lapu Day tragedy Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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20 Jan 2026 PHOENIX Zdravotnícke zásobovanie, a.s.; TRANSMEDIC SLOVAKIA, s.r.o. (in Konkurs)Pharmaceutical cartel uncovered thanks to whistleblower: 7.8 million EUR against PHOENIX and TRANSMEDIC €7.8m
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).
Whistleblowers receive a reward in Slovakia – internal reporting channels should be faster than the route to the authority.
Bid rigging in public tenders; whistleblowing channels
- 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
- KARTELY: PMÚ aj vďaka whistleblowerovi odhalil kartel v dodávkach liekov a uložil pokuty takmer 7,8 milióna eur Press release of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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22 Dec 2025 New York-Presbyterian Hudson Valley HospitalNYP Hudson Valley Hospital: 6.8 million USD for payments to referring practice €5.79m
The hospital (until 2015 Hudson Valley Hospital Center) allegedly paid an oncology practice in Westchester millions of dollars to induce it to refer patients to the hospital; the hospital billed the services to Medicare and Medicaid. The U.S. Attorney’s Office filed a complaint and at the same time concluded a settlement of 6.8 million USD.
Cooperation agreements between hospitals and office-based practices must properly document services and remuneration – otherwise payments are treated as referral bonuses.
Payments to referrers in hospitals
- Authority / court
- U.S. Attorney's Office, Southern District of New York
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 6,800,000 USD, converted at the ECB reference rate of 22 Dec 2025.
- HHS-OIG Enforcement Actions: U.S. Attorney Announces $6.8 Million Settlement With New York-Presbyterian Hudson Valley Hospital … (22.12.2025) Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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3 Dec 2025 Southern Health Solutions, Inc. (Next Medical / NextMed)NextMed: FTC settlement over allegations of hidden costs and review manipulation €128,557
According to the FTC, the telemedicine company advertised GLP-1 weight-loss programmes with monthly prices that did not include medication, laboratory costs and medical consultations, concealed the minimum term and cancellation fees, published fake testimonials from employees and relatives, and induced customers to delete negative reviews by offering vouchers or refunds. Under the final settlement order, the company is paying 150,000 USD jointly with other liable parties (joint payment), which is earmarked for refunds.
"Buying off" negative reviews with vouchers is just as misleading as inventing positive ones.
Review manipulation and price disclosures
- Authority / court
- Federal Trade Commission (FTC)
- Area of law
- Consumer protection and online retail · Fake reviews
- Legal basis
- Section 5 FTC Act; Restore Online Shoppers' Confidence Act (ROSCA)
- Action
- Disgorgement of profits
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Measures against individuals are not reported here.
- Published
- 3 Dec 2025
Original amount 150,000 USD, converted at the ECB reference rate of 3 Dec 2025.
- FTC Takes Action Against Telemedicine Firm NextMed Press release of an authority
- FTC Approves Final Order against Telehealth Provider NextMed (03.12.2025) Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 3 · Direct link
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21 Nov 2025 IDCQ Hospitales y Sanidad, S.L.U.AEPD: €1.2m fine for hospital operator IDCQ over disposed patient scans €1.2m
A hospital of the group had removed from its archive earlier MRI scans that a patient had brought in for comparison once an internal collection period had expired, so that they were no longer available. The AEPD imposed 100,000 EUR each for processing health data without a legal basis (Art. 9 and Art. 6) and 1,000,000 EUR for lack of data protection by design in the procedure (Art. 25), 1,200,000 EUR in total.
Documents handed over by patients are health data and must not be destroyed under internal clear-out deadlines.
Handling health records handed over by patients
- Authority / court
- Agencia Española de Protección de Datos (AEPD)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Art. 6, 9, 25 DSGVO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 20 Mar 2026
- AEPD, Resolución PS/00288/2024 (EXP202402851), IDCQ Hospitales y Sanidad Decision of an authority
- BOE: Resolución de 4 de marzo de 2026 der AEPD, Sanktionen über 1 Mio. Euro Official register or notice
Checked against the official source on 28 Sep 2026 · Direct link
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13 Nov 2025 Lancet LaboratoriesInformation Regulator: ZAR 100,000 against Lancet Laboratories over unreported data breaches €5,062
An assessment following several security compromises found that the laboratory company had notified neither the Information Regulator nor the affected data subjects. After an enforcement notice that it failed to comply with, it received an infringement notice with an administrative fine of ZAR 100,000, which has since been paid.
Data breaches must be reported both to the regulator and to the data subjects; failing to report several incidents triggers an assessment and sanctions.
Notifying data breaches to the regulator and data subjects
- Authority / court
- Information Regulator (South Africa)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Protection of Personal Information Act 4 of 2013 (POPIA), s. 22
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Published
- 13 Nov 2025
Original amount 100,000 ZAR, converted at the ECB reference rate of 13 Nov 2025.
- Information Regulator: Media briefing – high-level cases on POPIA and PAIA (13.11.2025) Press release of an authority
Checked against the official source on 4 Oct 2026 · Direct link
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6 Nov 2025 DoctolibFrance: 4.665 million EUR against Doctolib for abuse in doctor appointment booking €4.67m
Doctolib tied doctors with exclusivity clauses, bundled telemedicine with the appointment booking subscription and in 2018 acquired its main competitor in order to eliminate it (decision 25-D-06). Fines: 4.615 million EUR for exclusivity and tying, 50,000 EUR for the acquisition.
Platforms with high market shares should have exclusivity clauses, bundled offers and acquisitions of rivals reviewed under competition law.
- 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
- L'Autorité de la concurrence sanctionne Doctolib à hauteur de 4 665 000 euros Press release of an authority
- Décision 25-D-06 relative à des pratiques mises en œuvre dans le secteur de la prise de rendez-vous médicaux en ligne Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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13 Oct 2025 Nura OÜNura OÜ must hand over scan files of their treatment to two patients Order
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.
Access requests concerning health data require a fixed procedure with deadlines – in small practices too.
Handling access requests from patients
- 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
- Ettekirjutus-hoiatus nr 2.1-1/25/737-1585-20 (Nura OÜ), 13.10.2025 Decision of an authority
- Andmekaitse Inspektsioon – veröffentlichte Ettekirjutused (Liste) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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8 Oct 2025 Australian Clinical Labs LimitedAustralian Clinical Labs: 5.8 million AUD civil penalty after Medlab Pathology data breach €3.28m
On the application of the Australian Information Commissioner, the Federal Court of Australia imposed the first civil penalties under the Privacy Act 1988: Australian Clinical Labs (ACL) had failed to adequately protect the personal information held on the IT systems of its Medlab Pathology business; in a cyberattack in February 2022, data of more than 223,000 people was taken from those systems. The penalty of 5.8 million AUD in total comprises 4.2 million AUD for the inadequate security measures (APP 11.1), 800,000 AUD because ACL did not assess reasonably and promptly whether a notifiable data breach had occurred, and 800,000 AUD for the late notification to the Commissioner. ACL admitted the contraventions; liability and the penalty were allegedly based on joint submissions by the parties.
When a business unit's IT systems are integrated into an organisation's own environment, they must be adequately protected from the outset, and attacks must be promptly assessed for a notification duty.
Securing integrated IT systems, assessing and notifying data breaches promptly
- Authority / court
- Office of the Australian Information Commissioner (OAIC)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Privacy Act 1988 (Cth) s 13G(a) i. V. m. APP 11.1; s 26WH(2); s 26WK(2)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- negligent
- Mitigating circumstances
- Cooperation with the investigation, an ongoing programme to uplift cyber security, apologies and admission of liability.
- Liability of senior managers
- The court found that the most senior management was involved in the decisions on integrating the Medlab systems and on assessing the attack.
- Published
- 9 Oct 2025
Original amount 5,800,000 AUD, converted at the ECB reference rate of 8 Oct 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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12 Sep 2025 Specer sp. z o.o.Medical company Specer: CEO acting as data protection officer costs 11,365 PLN €2,669
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.
This also applies in small practices and companies: management cannot be its own data protection officer.
Role and independence of the data protection officer; release of patient records
- 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.
- Prezes firmy nie może być jednocześnie IOD. Kara dla spółki Specer Press release of an authority
- Decyzja DKN.5131.7.2025 z 12 września 2025 Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Jul 2025 BGH: no before-and-after images for nose and chin correction with hyaluronic acid Order
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.
Instagram posts are also advertising – the strict limits of the law on advertising for medicinal products and treatments (Heilmittelwerberecht) apply to aesthetic procedures.
Social media advertising for healthcare services
- 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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26 Jun 2025 NUWAY Alliance, Inc.NUWAY Alliance: USD 18.5m over payments to Medicaid patients and double billing €15.8m
The Minnesota provider of outpatient addiction treatment pays USD 18,500,000 to resolve False Claims Act allegations and entered into a five-year Corporate Integrity Agreement with HHS-OIG. According to the US Attorney's Office, from January 2019 to February 2025 NUWAY compensated Medicaid patients for attending intensive outpatient treatment and also billed services in which the same period of time was counted twice. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Cash or in-kind incentives to patients for using reimbursable services are prohibited kickbacks under US law.
Incentives to patients for using reimbursable services
- Authority / court
- U.S. Attorney's Office, District of Minnesota (U.S. Department of Justice)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- False Claims Act; Anti-Kickback Statute
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Published
- 26 Jun 2025
Original amount 18,500,000 USD, converted at the ECB reference rate of 26 Jun 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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5 Jun 2025 23andMe, Inc.ICO: £2.31 million against 23andMe after credential stuffing targeting genetic data €2.74m
From April to September 2023, attackers used reused credentials to access data on 155,592 people in the United Kingdom, including ancestry, family trees and health information. There was no MFA, no secure password rules and no effective monitoring; despite anomalies in July 2023, the full investigation only began in October. Joint investigation by the UK Information Commissioner's Office (ICO) with the Privacy Commissioner of Canada.
Companies that manage genetic or health data must protect customer accounts against credential stuffing with MFA and investigate warning signs immediately.
- Authority / court
- Information Commissioner's Office (ICO)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- UK GDPR Art. 5 Abs. 1 lit. f, Art. 32 Abs. 1
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Employees
- 250 to 999
- Culpability
- negligent
- Published
- 17 Jun 2025
Original amount 2,310,000 GBP, converted at the ECB reference rate of 5 Jun 2025.
- 23andMe fined for failing to protect UK users' genetic data Press release of an authority
- ICO Penalty Notice: 23andMe, Inc. Decision of an authority
- SEC EDGAR: 23andMe Holding Co., Form 10-K zum 31.03.2025 (265 Beschäftigte) Official register or notice
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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27 May 2025 Yliopiston ApteekkiYliopiston Apteekki: 1.1 million EUR over tracking in online shop – court annuls fine overturned
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).
Tracking tools on health-related websites can easily transmit sensitive data – include marketing technology in the data protection review.
Tracking pixels on sensitive websites
- 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.
- Finlex – Tietosuojavaltuutettu 27.5.2025 (verkkoapteekin seurantateknologiat) Decision of an authority
- Tietosuojavaltuutettu – Hallinto-oikeudelta päätös Yliopiston Apteekille määrätystä seuraamusmaksusta (2.6.2026) Press release of an authority
- Helsingin hallinto-oikeus – kumosi Yliopiston Apteekille määrätyn 1,1 miljoonan euron seuraamusmaksun (01.06.2026) Court press release
Checked against the official source on 25 Sep 2026 · Direct link
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9 Apr 2025 Conselho Federal de Fisioterapia e Terapia Ocupacional (COFFITO)CADE: physiotherapy federal council COFFITO fined BRL 3.1m over price tables €464,087
The CADE Tribunal convicted the federal council of physiotherapists and occupational therapists because, through resolutions, rulings and annually updated reference tables, it had set binding minimum prices for the services of members of the profession and thereby encouraged uniform market conduct. In addition to a fine of 3,103,583.65 BRL, COFFITO must refrain from binding price tables, remove all references to them from its websites (penalty of 5,000.00 BRL per day) and publish the decision on its website and social media; proceedings against the regional council for the 15th region are suspended owing to a settlement. The amount and the facts have not been confirmed against the primary source.
Professional chambers and associations must not impose binding price tables on their members.
Fee and price recommendations by professional chambers
- Authority / court
- Conselho Administrativo de Defesa Econômica (CADE), Tribunal Administrativo
- Area of law
- Competition law · Cartels and collusion
- Legal basis
- Lei nº 12.529/2011; Art. 38 und 39 (Nebenanordnungen)
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 10 Apr 2025
Original amount 3,103,583.65 BRL, converted at the ECB reference rate of 9 Apr 2025.
- Diário Oficial da União, 16.04.2025, Seção 1, S. 78: Ata da 245ª Sessão Ordinária de Julgamento (09.04.2025), PA nº 08700.003473/2021-16 Official register or notice
- CADE, 10.04.2025: Tribunal do Cade condena Conselho de Fisioterapia por tabelamento de preços em serviços profissionais Press release of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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2 Apr 2025 Malta: 20,000 EUR against healthcare provider over electoral register data and missing DPO €20,000
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.
Anyone processing health data on a large scale needs a data protection officer – and a reported incorrect address must be corrected immediately.
Implementing rectification requests promptly
- 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
- IDPC Decision CDP/COMP/282/2024 Decision of an authority
- Data Protection Decisions – IDPC Enforcement database of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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31 Mar 2025 Attendo Suomi OyAttendo: EUR 1.5m after chats were deleted during a competition inspection €1.5m
The Markkinaoikeus (Market Court, Finland) imposed a penalty payment of 1,500,000 EUR on the care services provider Attendo Suomi Oy for obstructing an unannounced inspection by the competition authority in January 2023: after the inspection had begun, a manager deleted chat histories and the call log on a mobile phone also used for work. It was the first penalty for such a procedural infringement in Finland; the authority had sought 4,373,760 EUR, but the court gave considerably more weight to Attendo's own measures, including the swift restoration of the deleted chats.
Once an inspection starts, an immediate ban on deleting or altering data applies to all work devices and messaging apps – every manager must know this.
Conduct during unannounced inspections (dawn raids)
Missing or inadequate training played a role in the decision.
- Authority / court
- Markkinaoikeus (Marktgericht) auf Antrag des Kilpailu- ja kuluttajavirasto (KKV)
- Area of law
- Competition law
- Legal basis
- Kilpailulaki (948/2011) 37 a § 1 mom. 1 kohta i. V. m. 35 § und 37 §
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Mitigating circumstances
- Training and instructions for staff on conduct during inspections already before the incident; swift restoration and handover of the deleted chats from a backup; no advantage gained and no earlier penalties for procedural infringements.
- Published
- 31 Mar 2025
Checked against the official source on 28 Sep 2026 · Direct link
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6 Feb 2025 Медицински център „Люлин Мед“ ООДMC Lyulin Med presented practice as branch of the Military Medical Academy – 9,236 leva €4,722
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.
Cooperation with renowned institutions must not be presented as affiliation on signage and in online profiles.
- 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.
- КЗК Публичен електронен регистър – Производство (Решение № 131 от 06.02.2025; Volltext als PDF im Register) Official register or notice
Checked against the official source on 25 Sep 2026 · Direct link
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23 Jan 2025 C.R. Bard, Inc.; Liberator Medical Supply, Inc.; Liberator Holdings; Rochester Medical CorporationC.R. Bard: USD 17m over discounts and free samples for urology practices €16.3m
Bard and three affiliated companies pay USD 17 million to resolve allegations under the federal False Claims Act and several state statutes. Between 2016 and February 2020 they allegedly gave urology practices discounts, excessive free samples and savings on office supplies so that they would prescribe intermittent catheters by default using Bard's own “Link” prescription form; no liability was determined.
Free samples and discounts must never be linked to prescribing routes that benefit one's own sales.
Free samples and discounts in medical device sales
- Authority / court
- U.S. Attorney's Office, Northern District of Georgia (U.S. Department of Justice)
- Area of law
- Bribery and corruption · Gifts, hospitality and benefits
- Legal basis
- False Claims Act; Anti-Kickback Statute (42 U.S.C. § 1320a-7b); False-Claims-Gesetze mehrerer Bundesstaaten
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Published
- 23 Jan 2025
Original amount 17,000,000 USD, converted at the ECB reference rate of 23 Jan 2025.
Checked against the official source on 3 Oct 2026 · Direct link
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23 Jan 2025 Associação da Irmandade da Santa Casa de Misericórdia de PacaembuSanta Casa de Pacaembu: BRL 47.4m for fraud in hospital management contracts €7.65m
The Controladoria-Geral da União (CGU, Office of the Comptroller General) imposed on the Associação da Irmandade da Santa Casa de Misericórdia de Pacaembu, an association operating as a healthcare social organisation (Organização Social), a fine of BRL 47,391,386.87, extraordinary publication of the decision and a declaration of unsuitability for public contracts. According to the final report, the association rigged the selection procedure for managing the Hangar field hospital in Belém (Pará), committed fraud in performing the management contract for a regional hospital in Belém and used front persons and companies to conceal its real interests.
Associations that run hospitals on behalf of the state are also liable under the Anti-Corruption Law, and their leaders can be held personally liable.
Integrity in selection procedures and management contracts in healthcare
- Authority / court
- Controladoria-Geral da União (CGU)
- Area of law
- Bribery and corruption
- Legal basis
- Lei nº 12.846/2013, Art. 5 III und IV b und d, Art. 6, Art. 14; Lei nº 8.666/1993, Art. 87 IV und Art. 88 II und III
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Liability of senior managers
- Measures against individuals are not set out here.
- Published
- 28 Jan 2025
Original amount 47,391,386.87 BRL, converted at the ECB reference rate of 23 Jan 2025.
- DOU Seção 1 Nr. 19 vom 28.01.2025 (Faksimile, CGU Base de Conhecimento): Decisão nº 41 de 23.1.2025, PAR 00190.106781/2022-79 Decision of an authority
- DOU: CGU Decisão nº 58 de 2.3.2026 (Reconsiderações abgelehnt, Wirkungen der Decisão nº 41 bestätigt) Decision of an authority
- CGU: Relatório Final, PAR 00190.106781/2022-79 (Santa Casa de Pacaembu) Decision of an authority
Checked against the official source on 3 Oct 2026 · Direct link
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17 Dec 2024 Krankenhaus (anonymisiert)Hospital after ransomware: fine cut by court from €200,000 to €50,000 €50,000
Following a ransomware attack in 2021 – the second after an attack in 2019 – the Litigation Chamber found that a Belgian hospital had, among other things, no data protection impact assessment, no effective information security policy, no adequate procedure for security updates of its software and no genuine training and awareness programme for staff. On 17 December 2024 it imposed a fine of 200,000 EUR, ordered remedial measures and rejected the argument that, as a public body, the hospital could not be fined. On 3 September 2025 the Market Court partially annulled the decision and reduced the fine to 50,000 EUR; the data protection authority has lodged an appeal in cassation against that judgment. The decision is not final. The amount and the facts have not been confirmed against the primary source.
A single phishing training session or the participation of a few employees in exercises does not replace regular data protection and security training for all hospital staff.
Security awareness and data protection training for all hospital staff
Missing or inadequate training played a role in the decision.
- Authority / court
- Autorité de protection des données / Gegevensbeschermingsautoriteit (APD/GBA) – Chambre Contentieuse
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Art. 5 Abs. 1 lit. f, Art. 24, Art. 32 und Art. 35 Abs. 3 DSGVO; Art. 58 Abs. 2 lit. d und i sowie Art. 83 DSGVO; Art. 100 § 1 9° und 13° sowie Art. 101 LCA
- Action
- Fine
- Status of proceedings
- reduced
- Sector
- Healthcare
- Culpability
- negligent
- Mitigating circumstances
- The Chamber reduced the starting amount of 390,000 EUR to 200,000 EUR, mainly because of the hospital's financial difficulties, the Covid-19 crisis as a mitigating circumstance and a reassessed duration of the infringement.
Checked against the official source on 7 Oct 2026 · Version 2 · Direct link
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16 Dec 2024 Becton, Dickinson and Company (BD)Becton Dickinson: risks of Alaris infusion pump concealed – 175 million USD €166.7m
The medical technology manufacturer misled investors about regulatory risks of the Alaris infusion pump, which had more than 25 software defects, and did not record the remediation costs, as a result of which operating income in the fourth quarter of 2019 was overstated by 82 %. BD is paying 175 million USD and must appoint an independent compliance consultant.
Product and approval problems are capital market issues: quality and regulatory affairs departments must be involved in the disclosure process.
- Authority / court
- U.S. Securities and Exchange Commission (SEC)
- Area of law
- Capital markets and financial supervision · Disclosure and reporting obligations
- Legal basis
- Antifraud-, Reporting-, Buchführungs-, interne Kontroll- und Disclosure-Controls-Vorschriften der US-Wertpapiergesetze
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 175,000,000 USD, converted at the ECB reference rate of 16 Dec 2024.
- Becton Dickinson to Pay $175 Million for Misleading Investors About Alaris Infusion Pump Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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13 Dec 2024 United Lincolnshire Teaching Hospitals NHS TrustICO: Reprimand for United Lincolnshire Teaching Hospitals NHS Trust over late subject access responses Reprimand or warning
The ICO issued a reprimand to United Lincolnshire Teaching Hospitals NHS Trust. The ICO found that between March 2021 and March 2022 the trust failed to answer 32% of subject access requests within the one-month statutory deadline. The ICO found infringements of the requirements to respond on time.
- Authority / court
- Information Commissioner's Office (ICO)
- Area of law
- Data protection · Data subject rights and transparency
- Legal basis
- Art. 12(3), 15(1) und 15(3) UK GDPR; Art. 58(2)(b) UK GDPR
- Action
- Reprimand or warning
- Status of proceedings
- unknown
- Sector
- Healthcare
- Employees
- 1,000 to 9,999
- ICO Enforcement: United Lincolnshire Teaching Hospitals NHS Trust. Enthält Informationen des Information Commissioner's Office, lizenziert unter der Open Government Licence v3.0. Enforcement database of an authority
- Reprimand: United Lincolnshire Teaching Hospitals NHS Trust (13 December 2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 2 · Direct link
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12 Dec 2024 Oroville HospitalOroville Hospital: USD 10.25m over admission bonuses for doctors and false billing €9.77m
The Californian hospital pays USD 10,250,000 (USD 9,518,954 to the federal government, USD 731,046 to the State of California) and entered into a five-year Corporate Integrity Agreement with HHS-OIG. The allegations were that it paid doctors who decided on inpatient admissions bonuses based on the number of patients admitted, billed medically unnecessary inpatient admissions and used false diagnosis codes for SIRS. The authority allegedly made the findings set out here; this account is not based on a final judgment.
Bonus schemes for doctors must not be linked to the number of admissions or referrals.
Bonus schemes for doctors and referral incentives in hospitals
- Authority / court
- U.S. Attorney's Office, Eastern District of California (U.S. Department of Justice)
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- False Claims Act; Anti-Kickback Statute
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Published
- 12 Dec 2024
Original amount 10,250,000 USD, converted at the ECB reference rate of 12 Dec 2024.
Checked against the official source on 3 Oct 2026 · Direct link
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16 Oct 2024 DSB: 5,000 EUR against Covid laboratory with managing director as data protection officer €5,000
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.
Whoever decides on the purposes and means of processing cannot monitor themselves as data protection officer.
- 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.
- DSB Straferkenntnis GZ 2024-0.641.771 vom 16.10.2024 (RIS) Decision of an authority
Checked against the official source on 25 Sep 2026 · Direct link
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1 Oct 2024 a Danish non-profit health organisationNon-profit health organisation: 75,000 DKK after theft of unencrypted laptops €10,057
A Danish non-profit health organisation reported thefts of computers from its offices as well as phishing attacks in 2019 and 2020; according to the Danish Data Protection Agency (Datatilsynet), at least 1,448 people were affected, some with health data. Although the organisation itself had considered multi-factor authentication necessary after an attack in 2018, this and encryption of the computers were lacking. A Danish city court issued a final judgment ordering it to pay 75,000 DKK (Datatilsynet's recommendation and the prosecution's request: 800,000 DKK).
Encrypt mobile devices holding health data; repeated incidents without implementing one's own measures weigh heavily.
Encryption of mobile devices and phishing defence (multi-factor authentication)
- Authority / court
- Københavns Byret (auf Anzeige der Datatilsynet)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- DSGVO Art. 32 Abs. 1; databeskyttelsesloven § 41
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Repeat case
- yes
Original amount 75,000 DKK, converted at the ECB reference rate of 1 Oct 2024.
- Datatilsynet, Entscheidungen (Übersicht) (Entscheidung 2024) Press release of an authority
- Domsdatabasen, Urteilsdatenbank (Suche) (Entscheidung 2024) Court decision
Checked against the official source on 28 Sep 2026 · Version 3 · Company name anonymised since 1 Oct 2026 · Direct link
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24 Sep 2024 a New Zealand aged care providerNew Zealand aged care provider: publicly named for notifying a privacy breach two years late Other
At one of the provider's care facilities, part of a resident's paper file was lost, which came to light during a special audit in August 2021. Although staff considered the incident notifiable and the health board and later the Health and Disability Commissioner (health complaints authority) urged notification, the company only informed the Office of the Privacy Commissioner (OPC, New Zealand's data protection authority) in October 2023. On 24 September 2024 the Privacy Commissioner found a breach of the notification duty and poor document management and named the company publicly.
Every loss of data must be assessed immediately for notifiability – even a single lost health file can be a notifiable breach.
Recognising and notifying privacy breaches on time
Missing or inadequate training played a role in the decision.
- Authority / court
- Office of the Privacy Commissioner (OPC)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Privacy Act 2020, s 114
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Constructive engagement; introduction of an electronic document management system with access controls, staff training, a privacy breach management plan and a revised management structure.
- Published
- 24 Sep 2024
- Office of the Privacy Commissioner, Decision notes (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Company name anonymised since 24 Sep 2026 · Direct link
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18 Sep 2024 a Latvian state university hospitalUniversity hospital refuses information to data protection authority – 2,000 EUR €2,000
The Datu valsts inspekcija (Latvian Data State Inspectorate, DVI) examined several complaints against the state hospital, including about the processing of patient and health data by a physician assistant and about an unanswered access request. Because the hospital did not provide the requested information, the authority imposed 2,000 EUR for breach of the duty to cooperate.
Hospitals need logged access to patient records and a central office that responds to supervisory requests on time.
Access to patient data only where related to treatment
- Authority / court
- Datu valsts inspekcija (DVI)
- 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
- Culpability
- intentional
- DVI, Entscheidungen (Übersicht) (Entscheidung 2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Sep 2026 · Direct link
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13 Sep 2024 Croatia: 190,000 EUR against specialist hospital after loss of X-ray images without backup €190,000
In 2019, a specialist hospital in the Rijeka area (name not published) irretrievably lost patients’ radiological images because it did not make backup copies, and did not report the incident although management had been informed. The Agencija za zaštitu osobnih podataka (Croatian Personal Data Protection Agency, AZOP) imposed 190,000 EUR, including for a missing data processing agreement, call recordings without a legal basis and failure to involve the data protection officer.
Backups are not a cost factor but an obligation – and a known data loss must be notified within 72 hours.
Notification of data breaches within 72 hours
- Authority / court
- Agencija za zaštitu osobnih podataka (AZOP)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Art. 5 Abs. 1 lit. e, Art. 6, 12, 13, 28 Abs. 3, 32 Abs. 1 lit. b, 33 Abs. 1, 38 Abs. 1 DSGVO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 13 Sep 2024
- AZOP, Nachrichten (Übersicht) (Entscheidung 2024) Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 13 Sep 2026 · Direct link
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9 Sep 2024 a US healthcare companySEC: healthcare company pays 1,386,000 USD over waivers of whistleblower awards €1.26m
Between July 2019 and July 2023, the healthcare company had employees waive potential awards for reports to authorities in 98 employment, separation, retention and settlement agreements; in 56 further separation and settlement agreements, they had to waive complaints to federal authorities. As part of a sweep against seven listed companies, the company paid 1,386,000 US dollars to the U.S. Securities and Exchange Commission (SEC); the contract templates were amended.
Separation and employment agreements must restrict neither reports to authorities nor the entitlement to whistleblower awards.
Whistleblower protection in contract templates (HR/Legal)
- Authority / court
- U.S. Securities and Exchange Commission
- Area of law
- Whistleblower protection · Retaliation against whistleblowers
- Legal basis
- Securities Exchange Act of 1934, Rule 21F-17(a)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Mitigating circumstances
- Partial amendment of the templates even before contact by the SEC, information provided to those affected, and cooperation
- Published
- 9 Sep 2024
Original amount 1,386,000 USD, converted at the ECB reference rate of 9 Sep 2024.
- SEC, Pressemitteilungen (Übersicht) (Entscheidung 2024) Press release of an authority
- SEC, Administrative Proceedings (Übersicht) (Entscheidung 2024) Decision of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 9 Sep 2026 · Direct link
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5 Sep 2024 a French medical practice software providerCNIL: €800,000 fine for medical software provider over health data without authorisation €800,000
The CNIL (French data protection authority) fined a French medical software provider EUR 800,000 because patient data were processed via its practice software for a health database without the authorisation required by Art. 66 of the Loi Informatique et Libertés (French Data Protection Act), and because data were also collected from the health insurance teleservice HRi, which only doctors may access (Art. 5(1)(a) GDPR). On 13 February 2026 the Conseil d'État (French supreme administrative court) dismissed the company's appeal and confirmed that the pseudonymised data are personal data because of the risk of re-identification.
Pseudonymised health data remain personal data as long as re-identification is possible with reasonable effort; databases containing them need the prescribed authorisation.
Pseudonymisation and health data
- Authority / court
- Commission nationale de l'informatique et des libertés (CNIL), formation restreinte
- Area of law
- Data protection
- Legal basis
- Art. 66 Loi n° 78-17 du 6 janvier 1978 (Loi Informatique et Libertés); Art. 5 Abs. 1 lit. a DSGVO
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- negligent
- Mitigating circumstances
- The company filed the required authorisation applications during the proceedings; no order was therefore issued.
- Published
- 12 Sep 2024
- CNIL, Les sanctions prononcées par la CNIL (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 5 Sep 2026 · Direct link
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29 Aug 2024 a Swedish pharmacy chainSwedish pharmacy chain: SEK 37m for unintended data transfer to Meta via the Meta Pixel €3.26m
The Integritetsskyddsmyndigheten (IMY, Swedish data protection authority) fined the pharmacy chain 37,000,000 SEK because, between 19 January 2020 and 25 April 2022, the company had not taken appropriate technical and organisational measures when using the Meta Pixel analytics tool on its website. Through the activated advanced matching function, contact details including personal identity numbers in hashed form, together with details of purchased, partly sensitive products, reached Meta when purchases were made; according to the incident report, an estimated 500,001 to 1,000,000 people were affected. The pharmacy chain learned of this through a tip-off from an outside party; the fine was based on its 2023 annual turnover of 23.27 billion SEK.
Anyone using marketing pixels must check every additional feature before activation for which customer data it transmits to the provider.
Tracking pixels and third-party tools on websites handling sensitive customer data
- Authority / court
- Integritetsskyddsmyndigheten (IMY)
- Area of law
- Data protection · Data breaches and data security
- Legal basis
- Art. 32 Abs. 1 DSGVO; Art. 58 Abs. 2 und Art. 83 DSGVO
- Action
- Fine
- Status of proceedings
- unknown
- Sector
- Healthcare
- Mitigating circumstances
- In assessing seriousness, IMY took into account that the data went in hashed form to a single recipient and that security measures were already in place; it treated notification, cooperation and subsequent remediation as neutral.
Original amount 37,000,000 SEK, converted at the ECB reference rate of 29 Aug 2024.
- IMY, Aufsichtsverfahren (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Company name anonymised since 29 Aug 2026 · Direct link
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28 Aug 2024 a French statistics companyCNIL: €800,000 fine for statistics company over health databases without authorisation €800,000
The CNIL (French data protection authority) fined a statistics company belonging to a French corporate group EUR 800,000 because it operated two databases containing health data from medical practices and from pharmacies without the authorisation required by Art. 66 of the Loi Informatique et Libertés (French Data Protection Act); at the end of March 2021 they held data on 13.4 million medical consultations with 4 million patient codes and around 78 million identifiers respectively. On 13 February 2026 the Conseil d'État (French supreme administrative court) dismissed the appeal, holding that the data were only pseudonymised and therefore personal data.
Anyone pooling health data from practice and pharmacy software for statistics cannot rely on pseudonymisation but needs prior authorisation from the supervisory authority.
Pseudonymisation and health data
- Authority / court
- Commission nationale de l'informatique et des libertés (CNIL), formation restreinte
- Area of law
- Data protection
- Legal basis
- Art. 66 Loi n° 78-17 du 6 janvier 1978 (Loi Informatique et Libertés)
- Action
- Fine
- Status of proceedings
- final
- Sector
- Healthcare
- Culpability
- negligent
- Mitigating circumstances
- The company filed the required authorisation applications during the proceedings; no order was therefore issued.
- CNIL, Les sanctions prononcées par la CNIL (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 7 Oct 2026 · Version 2 · Company name anonymised since 28 Aug 2026 · Direct link
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21 Aug 2024 a US provider of generative AI for hospitalsTexas obliges AI provider for hospitals to give honest accuracy claims Order
The Texas Attorney General's office concluded an Assurance of Voluntary Compliance with a Texas-based provider of generative AI for hospitals and submitted it to the court for approval. The provider had advertised the accuracy of its software, which summarises patient data for hospital staff, including with a 'severe hallucination' rate of less than 1 in 100,000; the authority considered these metrics likely to be inaccurate and misleading. For five years the provider must clearly explain such metrics in its advertising or have them substantiated by an independent auditor, and must disclose to its customers the risks, limitations and appropriate use of its products; the company denies any wrongdoing, and no payment is provided for.
Reliability metrics for AI need a disclosed definition and measurement method – and users must know when they should not rely on the system.
Performance claims for AI systems; limitations and appropriate use of AI in clinical practice
- Authority / court
- Office of the Attorney General of Texas, Consumer Protection Division
- Area of law
- AI and digital regulation · AI systems
- Legal basis
- Texas Deceptive Trade Practices–Consumer Protection Act (DTPA), Tex. Bus. & Com. Code §§ 17.41–17.63; Zusicherung nach § 17.58
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 18 Sep 2024
Checked against the official source on 8 Oct 2026 · Company name anonymised since 21 Aug 2026 · Direct link
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18 Jul 2024 a major US dialysis groupUS dialysis group: 34.5 million USD – kickbacks for referrals to dialysis centres and pharmacy €31.6m
The dialysis group allegedly paid kickbacks to promote referrals to its former pharmacy subsidiary and granted benefits to nephrologists and vascular surgeons to induce them to send patients to the group's dialysis centres. The group paid 34,487,390 USD.
Intra-group routing of customers to subsidiaries must not be bought with benefits for third parties.
Benefits for referrers
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
- Employees
- 10,000 or more
Original amount 34,487,390 USD, converted at the ECB reference rate of 18 Jul 2024.
- HHS OIG, Enforcement Actions (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 18 Jul 2026 · Direct link
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1 Jul 2024 three US home health agencies and their parent companyUS home health group: 4.5 million USD – kickbacks to senior living facilities and physicians €4.18m
Three home health agencies in Texas, Ohio and Indiana and their parent company allegedly granted kickbacks to assisted living facilities and physicians for Medicare referrals. They paid 4,496,330 USD.
Cooperation with facilities that refer customers requires written contracts with remuneration at market rates and regular review.
Benefits for cooperation partners who refer customers
- Authority / court
- U.S. Department of Justice
- Area of law
- Bribery and corruption · Commercial bribery
- Legal basis
- Anti-Kickback Statute (42 U.S.C. § 1320a-7b(b)); False Claims Act (31 U.S.C. §§ 3729 ff.)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 4,496,330 USD, converted at the ECB reference rate of 1 Jul 2024.
- HHS OIG, Enforcement Actions (Übersicht) (Entscheidung 2024) Enforcement database of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 1 Jul 2026 · Direct link
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12 Jun 2024 a Californian care facilityCalifornian care facility: 658,948 USD – care workers up to 24 hours without breaks €612,121
At the care facility, employees worked up to 24 hours a day, seven days a week, were not allowed to leave the premises, had to work through breaks and received no overtime pay. The settlement of 658,948 USD comprises 608,948 USD for 34 employees (including overtime and break premiums) and 50,000 USD in civil penalties.
Round-the-clock shifts without rest periods are a recurring pattern in care – rosters need checks against maximum working hours and breaks.
Working time limits and breaks in care
- Authority / court
- California Labor Commissioner's Office (Division of Labor Standards Enforcement)
- Area of law
- Health and safety and employment law · Working time
- Legal basis
- California Labor Code (Überstunden, Meal and Rest Periods, Mindestlohn)
- Action
- Other
- Status of proceedings
- final
- Sector
- Healthcare
Original amount 658,948 USD, converted at the ECB reference rate of 12 Jun 2024.
- California DIR, Medienraum (Übersicht) (Entscheidung 2024) Press release of an authority
Checked against the official source on 28 Sep 2026 · Version 4 · Company name anonymised since 12 Jun 2026 · Direct link
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6 Jun 2024 a Japanese medical corporationClinic operator: order over discounts in exchange for five-star Google Maps reviews Order
The medical corporation promised people attending an internal medicine clinic it operates for a flu vaccination a reduction in the vaccination fee if they rated the clinic with five or four stars on Google Maps. Consumers could not recognise the resulting reviews as advertising prompted by the provider; the order required it to stop displaying them, inform consumers and take preventive measures that also cover the medical staff.
Reviews obtained in exchange for discounts or other benefits are the provider's own advertising and must not appear as independent customer opinions.
Stealth marketing and incentivised reviews
- Authority / court
- Consumer Affairs Agency (消費者庁, CAA)
- Area of law
- Consumer protection and online retail · Fake reviews
- Legal basis
- Art. 7 Abs. 1 i. V. m. Art. 5 Nr. 3 (Bekanntmachung zu Stealth-Marketing) Act against Unjustifiable Premiums and Misleading Representations (不当景品類及び不当表示防止法, Gesetz Nr. 134/1962)
- Action
- Order
- Status of proceedings
- unknown
- Sector
- Healthcare
- Published
- 7 Jun 2024
- Consumer Affairs Agency (消費者庁, CAA), Veröffentlichung der Behörde (Entscheidung 2024) Decision of an authority
Checked against the official source on 8 Oct 2026 · Company name anonymised since 6 Jun 2026 · Direct link