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AI-based solution designed to automate personal data discovery and classification
Discover personal data across multiple systems in the cloud or on-premise
Harbor cooperation between DPO, Legal Services, IT and Marketing
Turn data subject request into an automated workflow with a clear insight into data every step of the way
Collaborate with stakeholders and manage DPIA and LIA in real-time with Assessment Automation
Guide your partners trough vendor management process workflow
Identifying the risk from the point of view of Data Subject
Quickly respond, mitigate damage and maintain compliance
Consolidate your data and prioritize your relationship with customers
Privacy portal allows customers to communicate their requests and preferences at any time
Introducing end-to end automation of personal data removal

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General Data Protection Regulation

Here you can find the official content of the Regulation (EU) 2016/679 (General Data Protection Regulation) in the current version. All Articles of the GDPR are linked with suitable recitals.

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€14.5 Million GDPR Fine for Non-compliant Data Retention Schedule

Non-compliant Data Retention Schedule

The Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit ) has issued a €14.5 million GDPR fine to German company Deutsche Wohnen SE. The fine was issued on October 30th, 2019.

What we would like to talk about is the reason behind the fine. As stated in the official press release by the Berlin DPA:

“During on-site inspections in June 2017 and March 2019, the supervisory authority found that the company used an archive system for the storage of personal data of tenants that did not provide the possibility of removing data that was no longer required.[…] In some of the individual cases that were examined, it was, therefore, possible to find years-old private data from tenants that were preserved, although they were no longer necessary for the purpose of their original collection. “

The reason behind the €14.5 million GDPR fine

The reason for this multi-million fine may lie in the Berlin Commissioner for Data Protection’s recommendation to adjust the archive systems during the first inspection in 2017.

However, the company could not fix the issue (although the effort was made, it just didn’t suffice). The fact is – that the data removal process introduces a set of new challenges for a DPO, amplified by the lack of understanding about where the data is stored and no real insight into the technical and business implications of data removal.

When a company is processing a large amount of data across multiple systems, automation is the only way to avoid the possibility of human error and reduce the risk of non-compliance.

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Nonetheless, there were other factors involved:

“…The specific determination of the amount of the fine, the Berlin Commissioner for Data Protection has used the legal criteria, taking into account both aggravating and mitigating factors. The fact that Deutsche Wohnen SE had deliberately set up the archive structure in question and that the data concerned had been processed in an inadmissible manner over a long period of time…”

We have been discussing the importance of compliant data removal for a while now. However, this is what we continuously observe. The indifference towards certain parts of the compliance process until it is too late and the fine is issued.

However, it is never too late. Start reading our blogs to better understand the GDPR-compliant data removal orchestration.

Read the blog: GDPR Requirements for Compliant Data Removal

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