According to the definition of data processing in the GDPR, processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The definition also gives examples of activities that shall be regardad as processing.…
Data protection vs. freedom of expression and information
The Hungarian DPA (NAIH) published two decisions (NAIH/2020/1154 and NAIH/2020/838) in connection with the list of the 50 wealthiest Hungarians and the list of the biggest family-owned businesses published by Forbes Hungary. The amounts of the fines were EUR 5,780 (HUF 2,000,000) and EUR 7,225 (HUF…
International data transfers after Schrems II
One of the most important data protection related news this summer is the European Court of Justice's judgment in Schrems II case published on 16th of July (Case C-311/18, Data Protection Commissioner v Facebook Ireland Ltd, and Maximillian Schrems).
The judgment contains the following main…
Takeaways from the (so far) highest GDPR fine in Hungary
At the beginning of June, the Hungarian DPA published a decision imposing an administrative fine of HUF 100 million (approx. EUR 290,000) under the GDPR. The fine was much higher than the data protection fines imposed in Hungary so far (the highest amount of fines previously imposed was HUF 30…
GDPR fines in Hungary imposed in 2020
While the amount of administrative fine in the GDPR is only a theoretical maximum, fines imposed in specific cases could serve as important practical compass in several respects: on the one hand, the level of fines is indicative itself, and on the other hand, it is also important for data…
Online conference of DPOs in Hungary
It is a legal obligation of the Hungarian Data Protection Authority (NAIH) to organise the annual conference of data protection officers (DPOs). Due to the obligations in the GDPR regarding the appointment of DPOs, the number of DPOs registered by the Hungarian DPA increased significantly,…
Quo vadis e-Privacy Regulation?
On November 22, the Permanent Representatives Committee of the Council of the European Union (COREPER) rejected the Council’s position on the draft e-Privacy Regulation. This means that the acceptance of the long-awaited e-Privacy Regulation that should complement the GDPR is still not on the…
The German DPAs' new concept on calculating GDPR fines
The Conference of the independent Data Protection Authorities of Germany (Konferenz der unabhängigen Datenschutzaufsichtsbehörden des Bundes und der Länder; DSK) published its generally applicable principles on imposing GDPR fines on companies. By publishing its concept, the DSK follows the Dutsch…
Quantum supremacy and data protection
It was all over the news a few days ago that Google had reached the quantum supremacy in an experiment, where a quantum processor proved that the figures pumped out by a random number generator were indeed random. This task took 3 minutes 20 seconds (200 seconds) for the quantum processor and…
The interpretation of the right of access in the practice of the Hungarian DPA
The right of access is an important guarantee in the GDPR to ensure the transparency of data processing for data subjects. However, it is an open question to what extent this right can be exercised. In the past months, several interpretations became available, mostly from German data protection…