UODO (Poland) - DKN.5131.24.2025
Poland's UODO fines court bailiff for GDPR violations regarding DPO.
Poland's data protection authority (UODO) has fined a court bailiff PLN 15,500 (€3,500) for violating GDPR. The violations included failing to publish and communicate the data protection officer's contact details to the UODO, and a conflict of interest where the bailiff also served as the DPO, undermining their independence.
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The lesson from this incident
Full lessonA court bailiff in Poland was fined €3,500 by UODO for two distinct GDPR violations: failing to publish and register the Data Protection Officer's contact details with the supervisory authority, and appointing themselves as their own DPO — a fundamental conflict of interest that undermines the independence the role requires. The DPO is designed to act as an independent overseer of data protection practices, and when the controller and DPO are the same person, that oversight becomes meaningless. This case highlights that GDPR compliance is not merely about technical safeguards but also about governance structures and administrative obligations. Even smaller organisations and individuals processing personal data professionally must meet these structural requirements or face regulatory sanctions.