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PolicySep 29, 2026

ANSPDCP (Romania) - TIP TOP FOOD INDUSTRY SRL

Romania's DPA fines TIP TOP FOOD INDUSTRY SRL €5,000 for unlawful biometric data processing.

The Romanian Data Protection Authority (ANSPDCP) fined TIP TOP FOOD INDUSTRY SRL €5,000 for violating GDPR principles. The company used employee fingerprints for time-and-attendance and access control without a proper legal basis, infringing on data minimization and lawfulness. The DPA ordered the company to replace the system with a less intrusive alternative.

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The lesson from this incident

Full lesson

TIP TOP FOOD INDUSTRY SRL collected and processed employee fingerprints for attendance and access control without establishing a valid legal basis under GDPR, violating Articles 5 and 6. Biometric data is classified as 'special category' data under GDPR Article 9, requiring explicit consent or another qualifying legal ground — none of which the company demonstrated. The core failure was deploying an intrusive biometric system without first conducting a legal and proportionality review, ignoring the data minimization principle. This case illustrates that convenience-driven technology adoption can carry significant legal and financial consequences when privacy-by-design principles are ignored from the outset.

Entities

ANSPDCP (vendor)time-and-attendance and access-control system (product)