[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"$fwi0PneDLJBWrrR8EaVBkU2UoC2805HB2X4EJway-ITU":3},{"article":4,"iocs":45,"watch_terms":46,"solutions":47,"lesson":50},{"id":5,"title":6,"slug":7,"summary":8,"ai_summary":9,"brief":10,"url":11,"image_url":12,"published_at":13,"ingested_at":14,"relevance_score":15,"entities":16,"category_id":23,"category":24,"article_tags":28},"1be4e54f-948f-48fd-9667-3102670665e3","UODO (Poland) - DKN.5131.24.2025","uodo-poland-dkn-5131-24-2025-3b2723","Minimal fix after newsletter review ← Older revision Revision as of 12:18, 7 October 2026 Line 84: Line 84: }} }} The DPA fined a court bailiff PLN 15,500 (€3,500) for a failure to communicate the contact details of its data protection officer to the DPA. The DPA also found that the data protection officer had a conflict of interests with its other tasks and duties. The DPA fined a court bailiff PLN 15,500 (€3,500) for a failure to communicate the contact details of its data protection officer to the DPA. The DPA also found that the data protection officer had a conflict of interests with their other tasks and duties. == English Summary == == English Summary ==","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.","Poland's DPA fines a court bailiff €3,500 for failing to notify DPO contact details and for conflict of interest.","https:\u002F\u002Fgdprhub.eu\u002Findex.php?title=UODO_(Poland)_-_DKN.5131.24.2025&diff=53324&oldid=53323","https:\u002F\u002Fgdprhub.eu\u002Fimages\u002F7\u002F7b\u002FLogoPL.png","2026-10-07T12:18:12+00:00","2026-10-07T14:01:31.346653+00:00",7,[17,20],{"name":18,"type":19},"UODO","vendor",{"name":21,"type":22},"GDPR","product","c5c77cdb-f7d7-4990-9436-c81dcbff1163",{"id":23,"icon":25,"name":26,"slug":27},null,"Policy","policy",[29,33,38,40],{"category":30},{"id":31,"icon":25,"name":21,"slug":32},"3f0f8451-91df-4b6c-9a73-ef3b2509b7f1","gdpr",{"category":34},{"id":35,"icon":25,"name":36,"slug":37},"53f9c4b6-8bc6-4964-9169-d09e5cd41d72","Compliance","compliance",{"category":39},{"id":23,"icon":25,"name":26,"slug":27},{"category":41},{"id":42,"icon":25,"name":43,"slug":44},"d95477d7-eb04-4fad-a2dc-be1428040ce7","Privacy Fines","privacy-fines",[],[18,21],{"controls":48,"vendors":49},[],[],{"slug":51,"title":52,"body":53,"framework_refs":54,"framework_notes":62},"polish-bailiff-fined-for-dpo-conflict-of-interest-and-failure-to-notify-uodo","Polish Bailiff Fined for DPO Conflict of Interest and Failure to Notify UODO","A 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.",[55,56,57,58,59,60,61],"GDPR Article 37 – Designation of the Data Protection Officer","GDPR Article 38 – Position of the Data Protection Officer","GDPR Article 39 – Tasks of the Data Protection Officer","GDPR Article 83(4) – Administrative fines for infringements of controller\u002Fprocessor obligations","NIST Privacy Framework PR.PO-P1 – Policies, processes, and procedures for managing privacy risks","CIS Control 14 – Security Awareness and Skills Training","ISO\u002FIEC 27701:2019 – Privacy Information Management (PIMS) roles and responsibilities",{}]