[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"$f4XAe_auHx_w-91stPYTuyrESVYIZeRvrYeGCSuSrjdQ":3},{"lesson":4},{"id":5,"slug":6,"article_id":7,"title":8,"body":9,"prevention":10,"framework_refs":11,"status":24,"created_at":25,"published_at":26,"article":27,"tags":31,"podcasts":50},"f1d8dd29-764d-4316-9006-634ae0c322ee","greece-hdpa-fines-ministry-and-processor-after-25m-record-breach-tied-to-known-vulnerabilities","f66a8cfe-04e5-4206-9db8-10a9c91d9b1e","Greece HDPA Fines Ministry and Processor After 2.5M-Record Breach Tied to Known Vulnerabilities","A data breach affecting approximately 2.5 million individuals was traced to known, unpatched vulnerabilities in systems operated by a third-party processor on behalf of a Greek government ministry. The HDPA found both the controller and processor liable, reinforcing that GDPR accountability cannot be outsourced or waived due to public-sector status or budget constraints. The breach involved encryption (likely ransomware) and possible data exfiltration, compounding the harm. This case underscores that known vulnerabilities represent an unacceptable and actionable risk, and that controllers must rigorously vet and monitor their processors' security posture.","**Immediate actions:**\n- Identify and remediate all known vulnerabilities (especially those listed in CISA KEV or equivalent national catalogs) in processor and controller systems without delay.\n- Conduct an emergency third-party security audit of all data processors handling personal data at scale.\n\n**Long-term improvements:**\n- Establish contractual SLAs in Data Processing Agreements (DPAs) that mandate timely patching and regular vulnerability assessments by processors.\n- Implement a continuous vulnerability management program covering both internal and third-party systems, with defined remediation windows based on severity.\n- Enforce a shared responsibility model so controllers actively verify processor compliance rather than assuming it.\n\n**Detection & response measures:**\n- Deploy network-level monitoring and data loss prevention (DLP) tools to detect anomalous encryption activity or large-scale data exfiltration early.\n- Test and rehearse incident response plans specifically for ransomware and exfiltration scenarios involving third-party processors.",[12,13,14,15,16,17,18,19,20,21,22,23],"GDPR Article 5(1)(f) – Integrity and confidentiality principle","GDPR Article 24 – Responsibility of the controller","GDPR Article 28 – Processor obligations and contractual requirements","GDPR Article 32 – Security of processing","GDPR Article 33 – Notification of a personal data breach","NIST SP 800-53 SI-2 (Flaw Remediation)","NIST SP 800-53 SA-9 (External Information System Services)","NIST CSF ID.RA-1 – Asset vulnerabilities identified and documented","CIS Control 7 – Continuous Vulnerability Management","CIS Control 15 – Service Provider Management","ISO\u002FIEC 27001:2022 Annex A 8.8 – Management of technical vulnerabilities","ISO\u002FIEC 27001:2022 Annex A 5.19 – Information security in supplier relationships","published","2026-09-08T12:21:44.137248+00:00","2026-09-08T12:21:44.035+00:00",{"id":7,"url":28,"slug":29,"title":30},"https:\u002F\u002Fgdprhub.eu\u002Findex.php?title=HDPA_(Greece)_-_15\u002F2026&diff=52947&oldid=52944","hdpa-greece-15-2026-aaa4e9","HDPA (Greece) - 15\u002F2026",[32,38,44],{"id":33,"name":34,"slug":35,"description":36,"color":37},"05757c8d-6b93-4194-b35d-7359e7d33b0e","Vulnerability Management","vulnerability-management","Missing scans, no risk prioritization","#fb923c",{"id":39,"name":40,"slug":41,"description":42,"color":43},"c0dcc566-3654-4d70-8ede-262a198e732f","Regulatory Compliance","regulatory-compliance","GDPR, NIS2, DORA, sector-specific violations","#ec4899",{"id":45,"name":46,"slug":47,"description":48,"color":49},"f0c2a0af-58aa-4128-87c9-6acd30f2dc48","Supply Chain","supply-chain","Third-party risk, compromised dependencies","#8b5cf6",[]]