Entering the next stage in GDPR compliance in Germany

  • Following the first GDPR fines issued in Austria and Portugal (and Britain’s ICO to follow soon), a German data protection authority has now issued the first such fine in the country – please consult the article about penalty fines under GDPR for more information on this topic.
  • More concerningly, some German data protection authorities have started sending out ‘questionnaires’ to businesses regarding their GDPR compliance – please consult the article about the current inspections of the Bavarian authorities.
  • At the same time, the anticipated wave of individuals ‘abusing’ their data subject rights and small businesses suing competitors for GDPR violations has not arrived, but it’s still too early for an ‘all-clear’ in this regard.

As most of the questions in these official questionnaires relate to the documentation requirements under the GDPR, we wanted to use this possibility to advise you to keep your data protection documentation up-to-date (register of processing activities, technical and organizational measures, data subject rights and data breach procedures, etc.).
Please let us know if you have any questions in this regard, or if there is anything we can help you with at this point. Please don’t hesitate to contact us at any time – we are happy to help!