HDPA (Greece) - 15/2026

Summary

Greece's Hellenic Data Protection Authority (HDPA) has fined both the Ministry of Social Cohesion and Family (controller) and the Hellenic Local Development and Local Government Company (processor) following a data breach that affected approximately 2.5 million individuals. The breach, which involved encryption and potential exfiltration of data, was attributed to known vulnerabilities in the processor's systems. The HDPA ruled that neither public interest nor lack of financial resources exempts organizations from their data security obligations under GDPR.

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Help HDPA (Greece) - 15/2026: Difference between revisions From GDPRhub Jump to:navigation, search ← Older editNewer edit →VisualWikitext Revision as of 09:56, 8 September 2026 view sourceSf (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators54 editsmTag: Visual edit← Older edit Revision as of 11:02, 8 September 2026 view source Ls (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators393 editsTag: Visual editNewer edit → Line 101: Line 101: === Facts ====== 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 the information systems operated by the processor were subject to a data breach.The Ministry of Social Cohesion and Family (the controller), and the Hellenic Local Development and Local Government Company (the processor) notified the DPA that information systems operated by the processor were subject to a data breach. During the breach, the databases supporting the implementation of two initiatives were encrypted and possibly downloaded/stolen. This included the data of staff, the legal representatives of the organisation, the applicants, and the beneficiaries (which included children) affecting a total of 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 data breach concerned databases used for the implementation of '''XXX'''. These databases included data relating to staff, legal representatives of the organisation, the applicants, and the beneficiaries of '''XXX''' (which included children) affecting a total of approximately 2,500,700 data subjects. The processor also suffered disruption of the systems. The controller underscored that the affected systems belonged to the processor who was in charge of actually implementing the program, blaming the incident on the processor. The controller further claimed that upon noticing the breach they immediately acted in compliance with the GDPR, notifying both the DPA and the processor, and took all necessary measures to restore the availability of the systems, and minimise the impact on data subjects. The controller blamed the incident on the processor and claimed that upon noticing the breach they immediately acted in compliance with the GDPR, notifying both the DPA and the processor, and took all necessary measures to restore the availability of the systems, and minimise the impact on data subjects. The processor admitted that it was aware of the risks that their systems pose, and the need for system improvement and update. The processor claimed that to remediate to these risks, it had previously requested the controller and other ministries to grant financial resources to modernise the information systems. The processor's financial resources in relation to the project were dependent entirely on state funding. The processor also argued that despite its awareness of the risks, it could not stop the processing in light of the public interest. The processor maintained that they could not stop the processing in light of the public interest, and made apparent that they were made aware of the risks that their systems pose, and the need for their information system technologies to be improved and updated. The processor 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 GDPR|Article 5(1)(f) GDPR]] and [[Article 32 GDPR]] ensuring the security, confidentiality and integrity of its systems. The DPA underscored that public interest and a lack of resources (financial) do not override the security obligation, and neither act as exemptions to this obligation.<u>The processor</u> The DPA held that the incident being the result of a known, reasonably foreseeable, and exploitable technical vulnerability, the processor violated its obligations to ensure data integrity, confidentiality and security, under [[Article 5 GDPR|Articles 5(1)(f)]] and [[Article 32 GDPR|32 GDPR]]. The DPA rejected the argument according to which the public interest prevented the processor from stopping the processing. It underscored that public interest and a lack of resources (financial) do not override the security obligation, and neither act as exemptions to this obligation. <u>The controller</u> 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 in advance that the measures implemented by the processor were adequate and correspondingly to choose a processor which can sufficiently guarantee the implementation of such measures. The controller therefore also violated [[Article 5 GDPR|Articles 5(1)(f)]] and [[Article 32 GDPR|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 in advance that the measures implemented by the processor were adequate and correspondingly to choose a processor which can sufficiently guarantee the implementation of such measures, thus acting in violation of [[Article 5 GDPR|Article 5(1)(f) GDPR]] and [[Article 32 GDPR]].<u>Absence of contract</u> Furthermore, in its investigation the DPA found that there was no active contract between the processor and the controller, covering the implementation of the initiatives and the associated 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 implementation of the initiatives and the associated processing operations, the DPA found both the controller and processor in violation of [[Article 28 GDPR|Article 28(3) GDPR]]. Revision as of 11:02, 8 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) notified the DPA that information systems operated by the processor were subject to a data breach. The data breach concerned databases used for the implementation of XXX. These databases included data relating to staff, legal representatives of the organisation, the applicants, and the beneficiaries of XXX (which included children) affecting a total of approximately 2,500,700 data subjects. The processor also suffered disruption of the systems. The contro

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