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PolicyJun 30, 2026

UODO (Poland) - DKN.5131.7.2022

Poland's DPA fined a sub-processor €2,415 for data security failures.

Poland's Data Protection Authority (UODO) fined a sub-processor €2,415 for failing to implement adequate technical and organizational measures to secure personal data. Former employees retained access to customer data shared via an app, constituting a data breach. The DPA also found the controller liable for not verifying processor compliance and for inadequate data protection agreements.

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The lesson from this incident

Full lesson

A Polish sub-processor failed to revoke application access for former employees, allowing them to continue viewing customer personal data after their employment ended. This constitutes both an access control failure and a breach of GDPR Article 32, which mandates appropriate technical and organizational measures to protect personal data. Compounding the issue, the data controller failed to verify that the processor had adequate safeguards in place and did not establish sufficiently robust data protection agreements. This case illustrates that GDPR accountability extends across the entire processor chain — controllers cannot delegate responsibility without active oversight. Offboarding procedures and processor audits are not optional compliance niceties; they are legally required safeguards.

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