News
πͺπΈPrivacy: Data disclosed by mistake
πͺπΈ π Error: HR Data Displayed on a Company Bulletin Board!
Source : PS 00467-2023
β €70,000 Fine by the AEPD
During union elections, the company INTERURBANA DE AUTOBUSES mistakenly displayed employees' personal data on a bulletin board instead of the electoral register.
π Facts
π’ An employee filed a complaint with the AEPD against their employer for disclosing personal data.
π Published information: name, surname, seniority date, date of birth, gender, postal address, etc.
π Data accessibility:
• Visible to employees but also from outside through a window.
• Risk of third-party consultation.
β οΈ The company acknowledged an HR department error, which disclosed a complete employee register instead of a simple electoral list. However, it disputes the accessibility of the data from outside.
π¨ Identified Violations
1οΈ Violation of the principle of data minimization (Article 5.1.c of the GDPR)
· β Unnecessary disclosure of personal information.
· π The AEPD emphasizes that even if only two addresses were disclosed, a single case is enough to constitute an infraction.
2οΈ Uncontrolled data accessibility
· ποΈ The data could be viewed by multiple individuals, including third parties.
· π οΈ Lack of technical and organizational measures to prevent this exposure.
3οΈ Lack of diligence in personal data management
· π Failure to implement measures ensuring data security and confidentiality.
· π Violation of Article 5.2 of the GDPR regarding proactive responsibility.
βοΈ Consequences and Sanctions
π° Fine: €70,000 for non-compliance with the data minimization principle.
π Obligation to comply: INTERURBANA DE AUTOBUSES must implement corrective measures within 6 months, or face further sanctions.
π’ Conclusion
β
This case highlights that companies must be vigilant in handling and displaying personal data.
β
Even an administrative error can lead to severe penalties in case of GDPR non-compliance. β
Implementing proper data protection measures is crucial to avoiding such situations.