[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"$fFtg9-XxTKuVM44UgvpolxRf-3Ow-urWKhhQVsVl_tqM":3},{"lesson":4},{"id":5,"slug":6,"article_id":7,"title":8,"body":9,"prevention":10,"framework_refs":11,"framework_notes":25,"status":26,"created_at":27,"published_at":28,"article":29,"tags":33,"podcasts":52,"controls":53},"a2749860-069f-4df8-820f-051ee15b3e9b","greek-dpa-fines-dei-and-call-center-partners-880k-for-gdpr-marketing-violations","02cc77b3-f9b6-4913-9c52-b397f5f0d303","Greek DPA Fines DEI and Call-Center Partners €880K for GDPR Marketing Violations","DEI S.A. and its call-center operators failed to implement adequate technical and organizational measures to respect data subjects' opt-out preferences, resulting in unlawful promotional calls to individuals registered on the national do-not-call list. A key failure was the unauthorized engagement of a subcontractor without proper authorization or oversight, violating GDPR's strict processor accountability requirements under Articles 28 and 29. Mixed-purpose calls—combining service and promotional content—further obscured consent boundaries and made it impossible to honor data subjects' objections effectively. This case illustrates that GDPR liability extends across the entire processing chain: controllers cannot delegate compliance responsibility to processors without rigorous contractual and operational controls. The €880,000 fine underscores that consent and objection management failures carry significant financial and reputational consequences.","**Immediate actions:**\n- Audit all active Data Processing Agreements (DPAs) to ensure processors and subcontractors are explicitly authorized and contractually bound to GDPR obligations.\n- Cross-reference contact lists against national opt-out registers and internal suppression lists before any outbound marketing campaign is launched.\n- Prohibit mixed-purpose calls (service + promotional) until separate consent mechanisms and call scripts are formally approved.\n\n**Long-term improvements:**\n- Establish a Vendor\u002FProcessor Risk Management program requiring security and compliance assessments before onboarding any subcontractor.\n- Implement a centralized consent and preference management platform that propagates opt-out signals in real time to all processors and subcontractors.\n- Conduct annual GDPR training for all staff and third-party operators involved in customer communications.\n\n**Detection & Monitoring measures:**\n- Deploy call monitoring and quality-assurance logging to detect non-compliant call scripts or unauthorized promotional content.\n- Set up automated alerts when a contact record flagged as opted-out is added to an outbound call queue.\n- Perform quarterly audits of processor activity logs to verify compliance with agreed data processing instructions.",[12,13,14,15,16,17,18,19,20,21,22,23,24],"GDPR Article 6 – Lawfulness of processing","GDPR Article 7 – Conditions for consent","GDPR Article 17 – Right to erasure \u002F objection handling","GDPR Article 21 – Right to object to direct marketing","GDPR Article 28 – Processor obligations and contracts","GDPR Article 29 – Processing under authority of controller or processor","GDPR Article 32 – Security of processing (technical and organizational measures)","NIST SP 800-53 PT-3 – Personally Identifiable Information Processing Purposes","NIST SP 800-53 SA-9 – External System Services \u002F Supply Chain Controls","CIS Control 3 – Data Protection","CIS Control 15 – Service Provider Management","ISO\u002FIEC 27001 Annex A.18.1 – Compliance with legal and contractual requirements","ITIL Service Design – Supplier Management Process",{},"published","2026-10-05T10:20:23.994468+00:00","2026-10-05T10:20:23.718+00:00",{"id":7,"url":30,"slug":31,"title":32},"https:\u002F\u002Fgdprhub.eu\u002Findex.php?title=HDPA_(Greece)_-_7\u002F2026&diff=53288&oldid=53161","hdpa-greece-7-2026-ed9319","HDPA (Greece) - 7\u002F2026",[34,40,46],{"id":35,"name":36,"slug":37,"description":38,"color":39},"c0dcc566-3654-4d70-8ede-262a198e732f","Regulatory Compliance","regulatory-compliance","GDPR, NIS2, DORA, sector-specific violations","#ec4899",{"id":41,"name":42,"slug":43,"description":44,"color":45},"c8b843a5-d5a7-41d1-8d3b-cabded09d2ef","Data Protection","data-protection","Unencrypted data, missing DLP, poor classification","#3b82f6",{"id":47,"name":48,"slug":49,"description":50,"color":51},"f0c2a0af-58aa-4128-87c9-6acd30f2dc48","Supply Chain","supply-chain","Third-party risk, compromised dependencies","#8b5cf6",[],[54,58],{"slug":55,"name":56,"problem":57},"data-loss-prevention","Data loss prevention (DLP)","Sensitive data cannot quietly leave by email, upload, USB stick or AI tool.",{"slug":59,"name":60,"problem":61},"compliance-automation","Compliance automation (GRC)","Evidence for NIS2, DORA and ISO 27001 is collected continuously, not in a rush before the audit."]