[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"$fBraDQGF2i8OOc7BWvsj6MfNVcSqATRJv_yqdZcEk1j0":3},{"article":4,"iocs":44},{"id":5,"title":6,"slug":7,"summary":8,"ai_summary":9,"brief":10,"full_text":11,"url":12,"image_url":13,"published_at":14,"ingested_at":15,"relevance_score":16,"entities":17,"category_id":21,"category":22,"article_tags":26},"2c524517-7cf8-483a-a0ca-9e02f08aebb8","HDPA (Greece) - 33\u002F2020","hdpa-greece-33-2020-1ddfc9","Standardized names and links ← Older revision Revision as of 11:59, 24 July 2026 Line 49: Line 49: |EU_Law_Name_1=Article 8(1) Charter of Fundamental Rights of the EU |EU_Law_Name_1=Article 8(1) Charter of Fundamental Rights of the EU |EU_Law_Link_1=https:\u002F\u002Feur-lex.europa.eu\u002Flegal-content\u002FHR\u002FTXT\u002F?uri=celex:12012P\u002FTXT |EU_Law_Link_1=http:\u002F\u002Fdata.europa.eu\u002Feli\u002Ftreaty\u002Fchar_2012\u002Foj |EU_Law_Name_2=ARTICLE 29 Working Party's Guidelines on the application and setting of administrative fines (wp253) |EU_Law_Name_2=ARTICLE 29 Guidelines on the application and setting of administrative fines for the purposes of the Regulation 2016\u002F679 (wp253) |EU_Law_Link_2=https:\u002F\u002Fec.europa.eu\u002Fnewsroom\u002Farticle29\u002Fitem-detail.cfm?item_id=611237 |EU_Law_Link_2=https:\u002F\u002Fec.europa.eu\u002Fnewsroom\u002Farticle29\u002Fredirection\u002Fdocument\u002F80836 |National_Law_Name_1=Articles 250-253 Civil Law Code |National_Law_Name_1=Articles 250-253 Civil Law Code","The Hellenic Data Protection Authority (HDPA) has fined the American College of Greece €2000 for violating a former employee's data subject rights. The college was found to have partly violated the complainant's right to access their data and failed to meet response deadlines for both access and erasure requests, resulting in two separate fines of €1000 each.","HDPA fines American College of Greece €2000 for violating data access and erasure rights.","Help HDPA (Greece) - 33\u002F2020: Difference between revisions From GDPRhub Jump to:navigation, search ← Older editVisualWikitext Revision as of 15:37, 6 December 2023 view sourceAr (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators2,246 editsm ← Older edit Latest revision as of 11:59, 24 July 2026 view source Sfl (talk | contribs)Bureaucrats, Interface administrators, noContributionReport, Administrators500 editsm Tag: Visual edit Line 49: Line 49: |EU_Law_Name_1=Article 8(1) Charter of Fundamental Rights of the EU|EU_Law_Name_1=Article 8(1) Charter of Fundamental Rights of the EU |EU_Law_Link_1=https:\u002F\u002Feur-lex.europa.eu\u002Flegal-content\u002FHR\u002FTXT\u002F?uri=celex:12012P\u002FTXT|EU_Law_Link_1=http:\u002F\u002Fdata.europa.eu\u002Feli\u002Ftreaty\u002Fchar_2012\u002Foj |EU_Law_Name_2=ARTICLE 29 Working Party's Guidelines on the application and setting of administrative fines (wp253)|EU_Law_Name_2=ARTICLE 29 Guidelines on the application and setting of administrative fines for the purposes of the Regulation 2016\u002F679 (wp253) |EU_Law_Link_2=https:\u002F\u002Fec.europa.eu\u002Fnewsroom\u002Farticle29\u002Fitem-detail.cfm?item_id=611237|EU_Law_Link_2=https:\u002F\u002Fec.europa.eu\u002Fnewsroom\u002Farticle29\u002Fredirection\u002Fdocument\u002F80836 |National_Law_Name_1=Articles 250-253 Civil Law Code |National_Law_Name_1=Articles 250-253 Civil Law Code Latest revision as of 11:59, 24 July 2026 HDPA - 33\u002F2020 Authority: HDPA (Greece) Jurisdiction: Greece Relevant Law: Article 4(7) GDPR Article 5 GDPR Article 12 GDPR Article 15 GDPR Article 17 GDPR Article 17(3)(e) GDPR Article 23 GDPR Article 51 GDPR Article 55 GDPR Article 57(1)(f) GDPR Article 58 GDPR Article 83 GDPR Article 8(1) Charter of Fundamental Rights of the EUARTICLE 29 Guidelines on the application and setting of administrative fines for the purposes of the Regulation 2016\u002F679 (wp253)Articles 250-253 Civil Law CodeArticle 95 Law 4387\u002F2016Article 9 Law 4624\u002F2019Article 13(1)g Law 4624\u002F2019Article 15 Law 4624\u002F2019Article 9Α Greek ConstitutionArticle 33 Law 4624\u002F2019HDPA Decision 73\u002F2010HDPA Decision 4\u002F2005HDPA Decision 39\u002F2005HDPA Decision 4\u002F2003HDPA Decision 43\u002F2003Article 5 Law 2472\u002F1997HDPA Opinion 4\u002F2009HDPA Opinion 6\u002F2013HDPA Decision 8\u002F2019Article 13(2) Law 2472\u002F1997Article 34 Law 4624\u002F2019 Type: Complaint Outcome: Partly Upheld Started: Decided: Published: 29.10.2020 Fine: 2000 EUR Parties: American College of Greece National Case Number\u002FName: 33\u002F2020 European Case Law Identifier: n\u002Fa Appeal: n\u002Fa Original Language(s): Greek Original Source: HDPA (in EL) Initial Contributor: Zarogianni Fotini The Hellenic Data Protection Authority (HDPA) issued two fines of €1000 each, against the American College of Greece for violating a data subject's rights to access and erasure. The HDPA examined a complaint of a former employee of the American College of Greece against the latter for the violation of the right to access and right to erasure of personal data of the former. The HDPA, after examining the merits of the case, decided that the American College of Greece partly violated the complainant's right to access their data and, for this reason, it ordered the College to proceed with the provision or said data, that the College violated the deadlines provided for responding to a request for access to personal data and, for this reason, a fine of €1000 was imposed, and that the College violated the deadlines provided for responding to a request for erasure of data and, for this reason, a fine of €1000 was imposed. Contents 1 English Summary 1.1 Facts 1.2 Dispute 1.3 Holding 2 Comment 3 Further Resources 4 English Machine Translation of the Decision English Summary Facts The data subject was under the employment of the College for a certain period of time, during which two female students of the College filed a complaint against the complainant regarding the latter's posts on social media that violated the College's Code of Conduct due to their homophobic and racist content. After this event, the College decided to move the complainant to a different position, while reacting to this situation the complainant argued that he had suffered a defamation by the College and requested the altering of the situation. The College asked the complainant to appear to the new position, something the complainant never did, but, nevertheless, the College continued paying the complainant's salary up to the ending point of their contract. Then, the data subject\u002Fcomplainant filed a request to the American College of Greece, asking for access to and copies of their personal data the latter is keeping in its records given the employment relationship between the two, while they specifically requested access to the two complaints made by the two students. With the same request, the data subject asked for the erasure of their personal data from the College's records, since the reason for which the data had been collected and were being kept was no longer valid, since the employment relationship between the complainant and the College had expired. In addition, with the same request, the complainant revoked their - possibly given silently - consent for the keeping and processing of their personal data by the College. The complainant claimed that there was no response from the College to their request. The HDPA requested the College's response to the situation. The latter claimed that the request under question only came into its attention via the HDPA's request for response to the claims. It justified this situation by mentioning that the employee who received the request was not in a good state of health, while the period when the request was filed was a period of heavy workload at the College. The College further underlined that, as soon as the request came to its attention, it contacted the complainant and: i) fulfilled their right to access their data by informing them for all data currently kept by the College and for providing information on how to get copies of all personal data, but not for the data referring to the personal information of one female student of the College who had filed a complaint against the data subject\u002Fcomplainant regarding the latter's behaviour, since the student expressed her not willingness for her name and complained to be known. The College also sent a question to the HDPA regarding the existence or not of their legal responsibility to provide access to the details of the complaint made by the student who expressed her not willingness to be known, as well as regarding the conditions under which such an access should be provided. This question, as the HDPA found, was never answered. ii) informed the complainant that the right to erasure could only be partly fulfilled, since some of the personal data being kept by the College must continue being kept due to the existence of the legal necessity for their existence, in order for the College to be able to fulfil some of its legal responsibilities, according to the provisions of Article 17(3)f GDPR, 250-253 Civil Law Code, and 95 Law 4387\u002F2016. Moreover, the College claimed that it had the right to deny the fulfilment of the complainant's right to access and erasure, according to article 12(5)b GDPR, since the respective request has been made in a manifestly unfounded or excessive and repetitive manner. Answering to the College's claims, the complainant argued that the College is not fulfilling their rights to access and erasure, as well as that the College is not properly justifying the excessive or unfounded manner of the complainant's requests based on the said GDPR article. Additionally, the complainant argued that their right to access had never been fulfilled as their relevant request to the College was only answered by the latter with the explanation that the College had sent a question to the HDPA regarding the legality of fulfilling such a request, but with no information being provided later on by the College. Thus, the complainant underlined that, under Article 55 of Law 4629\u002F2019, the College had the le","https:\u002F\u002Fgdprhub.eu\u002Findex.php?title=HDPA_(Greece)_-_33\u002F2020&diff=52472&oldid=36976","https:\u002F\u002Fgdprhub.eu\u002Fimages\u002F4\u002F49\u002FLogoGR.jpg","2026-07-24T11:59:57+00:00","2026-07-24T12:00:18.1669+00:00",7,[18],{"name":19,"type":20},"American College of Greece","vendor","3f0f8451-91df-4b6c-9a73-ef3b2509b7f1",{"id":21,"icon":23,"name":24,"slug":25},null,"GDPR","gdpr",[27,29,34,39],{"category":28},{"id":21,"icon":23,"name":24,"slug":25},{"category":30},{"id":31,"icon":23,"name":32,"slug":33},"53f9c4b6-8bc6-4964-9169-d09e5cd41d72","Compliance","compliance",{"category":35},{"id":36,"icon":23,"name":37,"slug":38},"c5c77cdb-f7d7-4990-9436-c81dcbff1163","Policy","policy",{"category":40},{"id":41,"icon":23,"name":42,"slug":43},"d95477d7-eb04-4fad-a2dc-be1428040ce7","Privacy Fines","privacy-fines",[]]