HDPA (Greece) - 15/2026

Summary

Greece's Hellenic Data Protection Authority (HDPA) has fined a data controller €200,000 and a data processor €150,000 for violating GDPR. The violations stemmed from a known, exploitable technical vulnerability that led to an incident. The processor cited a lack of state funding for system modernization, but the HDPA ruled that public interest and resource limitations do not exempt entities from security obligations.

Full text

Help HDPA (Greece) - 15/2026: Difference between revisions From GDPRhub Jump to:navigation, search VisualWikitext Revision as of 12:58, 3 September 2026 view sourceSf (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators46 edits Tag: Decisions [1.0] Latest revision as of 12:59, 3 September 2026 view source Sf (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators46 editsmTag: Visual edit Line 28: Line 28: |Date_Published=|Date_Published= |Year=2026|Year=2026 |Fine=200000.0|Fine=200,000 + 150,000 |Currency=EUR|Currency=EUR Line 108: Line 108: The processor was made aware of the risks that its systems pose, and the need for their information system technologies to be improved and updated. Within which they claimed that they contacted the controller and other ministries to secure the necessary resources to allow the processor to address the vulnerabilities of its system. The processor emphasised it didn’t have the necessary financial resources to modernise the information systems, which was dependent entirely on state funding.The processor was made aware of the risks that its systems pose, and the need for their information system technologies to be improved and updated. Within which they claimed that they contacted the controller and other ministries to secure the necessary resources to allow the processor to address the vulnerabilities of its system. The processor emphasised it didn’t have the necessary financial resources to modernise the information systems, which was dependent entirely on state funding. === Holding ====== Holding === The DPA held in light of the incident being the result of a known, reasonably foreseeable, and exploitable technical vulnerability, the processor violated Article 5(1)(f) and [[Article 32 GDPR|Article 32 GDPR]] ensuring the security of its systems. The DPA emphasised that public interest and a lack of resources do not override the security obligation, and neither act as exemptions to this obligation.The DPA held in light of the incident being the result of a known, reasonably foreseeable, and exploitable technical vulnerability, the processor violated [[Article 5 GDPR|Article 5(1)(f) GDPR]] and [[Article 32 GDPR]] ensuring the security of its systems. The DPA emphasised that public interest and a lack of resources do not override the security obligation, and neither act as exemptions to this obligation. The DPA further contended that a violation of [[Article 32 GDPR|Article 32 GDPR]] by the processor does not exempt the controller from its obligations. The DPA therefore held, that the controller failed to ensure that the measures were adequate and to select a processor which provides adequate safeguards, correspondingly acting in violation of [[Article 5 GDPR|Article 5(1)(f) GDPR]] and [[Article 32 GDPR|Article 32 GDPR]].The DPA further contended that a violation of [[Article 32 GDPR]] by the processor does not exempt the controller from its obligations. The DPA therefore held, that the controller failed to ensure that the measures were adequate and to select a processor which provides adequate safeguards, correspondingly acting in violation of [[Article 5 GDPR|Article 5(1)(f) GDPR]] and [[Article 32 GDPR]]. Furthermore, in its investigation the DPA found that there was no active contract between the processor and the controller, covering the initiatives and thus the processing operations, the DPA found both the controller and processor in violation of [[Article 28 GDPR|Article 28(3) GDPR]].Furthermore, in its investigation the DPA found that there was no active contract between the processor and the controller, covering the initiatives and thus the processing operations, the DPA found both the controller and processor in violation of [[Article 28 GDPR|Article 28(3) GDPR]]. As a result of the findings, the DPA imposed a fine of €200,000 on the data controller and 150,000 on the data processor, and ordered them to, effective immediately, enter into the contract required by [[Article 28 GDPR|Article 28(3) GDPR]].As a result of the findings, the DPA imposed a fine of €200,000 on the data controller and 150,000 on the data processor, and ordered them to, effective immediately, enter into the contract required by [[Article 28 GDPR|Article 28(3) GDPR]]. == Comment ==== Comment == ''Share your comments here!''''Share your comments here!'' Latest revision as of 12:59, 3 September 2026 HDPA - 15/2026 Authority: HDPA (Greece) Jurisdiction: Greece Relevant Law: Article 5(1)(f) GDPR Article 28(3) GDPR Article 32 GDPR Type: Other Outcome: n/a Started: Decided: 28.07.2026 Published: Fine: 200,000 + 150,000 EUR Parties: Υπουργείο Κοινωνικής Συνοχής και Οικογένειας Ελληνική Εταιρεία Τοπικής Ανάπτυξης και Αυτοδιοίκησης National Case Number/Name: 15/2026 European Case Law Identifier: n/a Appeal: n/a Original Language(s): Greek Original Source: DPA.GR (in EL) Initial Contributor: sf The DPA fined the controller €200,000 and the processor €150,000, after a large-scale data breach affecting 2,500,700 data subjects occurred, due to outdated information systems, and inadequate security measures. Contents 1 English Summary 1.1 Facts 1.2 Holding 2 Comment 3 Further Resources 4 English Machine Translation of the Decision English Summary Facts The Ministry of Social Cohesion and Family (the controller), and the Hellenic Local Development and Local Government Company (the processor) both notified the DPA after being subject to a data breach of the information systems operated by the processor. During the data breach, the databases supporting the implementation of two initiatives were encrypted and possibly downloaded/stolen. This included the data of staff, the legal representative of the organisation, the applicants, and the beneficiaries (which included children) affecting approximately 2,500,700 data subjects. The breach also allowed for unauthorised persons to gain access to the data held by the processor, and disruption of the systems. The controller claimed that it acted in compliance with the GDPR, notifying both the DPA and the processor immediately upon noticing the breach. The controller emphasised it took all necessary measures to address the incident, restore the availability of the systems, and minimise the impact on data subjects. The processor was made aware of the risks that its systems pose, and the need for their information system technologies to be improved and updated. Within which they claimed that they contacted the controller and other ministries to secure the necessary resources to allow the processor to address the vulnerabilities of its system. The processor emphasised it didn’t have the necessary financial resources to modernise the information systems, which was dependent entirely on state funding. Holding The DPA held in light of the incident being the result of a known, reasonably foreseeable, and exploitable technical vulnerability, the processor violated Article 5(1)(f) GDPR and Article 32 GDPR ensuring the security of its systems. The DPA emphasised that public interest and a lack of resources do not override the security obligation, and neither act as exemptions to this obligation. The DPA further contended that a violation of Article 32 GDPR by the processor does not exempt the controller from its obligations. The DPA therefore held, that the controller failed to ensure that the measures were adequate and to select a processor which provides adequate safeguards, correspondingly acting in violation of Article 5(1)(f) GDPR and Article 32 GDPR. Furthermore, in its investigation the DPA found that there was no active contract between the processor and the controller, covering the initiatives and thus the processing operations, the DPA found both the controller and processor in violation of Article 28(3) GDPR. As a result of the findings, the DPA imposed a fine of €200,000 on the data controller and 150,000 on the data processor, and orde

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