UODO (Poland) - DKN.5131.24.2025
Poland's DPA fines a court bailiff €3,500 for failing to notify DPO contact details and for conflict of interest.
Poland's Data Protection Authority (UODO) has fined a court bailiff PLN 15,500 (approximately €3,500) for two GDPR violations. The bailiff failed to communicate the contact details of its Data Protection Officer (DPO) to the DPA and was also found to have a conflict of interest due to performing both bailiff and DPO duties. The DPA imposed separate fines for each violation, totaling PLN 15,500.
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The lesson from this incident
Full lessonA court bailiff in Poland was fined PLN 15,500 for two distinct GDPR violations: failing to register the Data Protection Officer's contact details with the national supervisory authority, and allowing a single individual to simultaneously hold both the bailiff and DPO roles — a clear conflict of interest. GDPR Articles 37–39 mandate that the DPO must be able to perform their duties independently, which is structurally impossible when the DPO is also the controller or processor. This case highlights that GDPR compliance is not merely a technical exercise but requires proper organizational governance and role separation. Smaller organizations and sole practitioners are not exempt from these obligations and must proactively ensure both registration and independence requirements are met.