Ulrike Elteste

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New Calculation Model for Data Protection Fines in Germany

On October 16, 2019, the body of German Supervisory Authorities known as the Datenschutzkonferenz (“DSK”) released a document proposing a model for calculating fines under the GDPR.  The DSK indicated that this model is subject to change and will be superseded by any method put forward in guidance issued by the European Data Protection Board. … Continue Reading

New Calculation Model for Data Protection Fines in Germany

Update, September 19, 2019: Further to the reports on its scheme for calculating fines, which prompted requests on the supervisory to publish it, the Datenschutzkonferenz has clarified that fines in individual cases are calculated on the basis of Art. 83(2) GDPR, and that the model is only used on a complimentary basis. Furthermore, the model … Continue Reading

German Supervisory Authorities Issue Guidance on Data Subject Rights

Guidance on how to identify data subjects On July 1, 2019, the Bavarian Supervisory Authority for the public sector (“SA”) published guidance on how to verify the identity of data subjects exercising their data protection rights under the GDPR. The guidance is directed at public bodies, but is also helpful for private entities. According to … Continue Reading

German Supervisory Authority (re-)issues guidance on data processing in the employment context

The Supervisory Authority of Baden-Württemberg (“SA”), Germany, has published a new version of its guidance document on data protection issues in the employment context on March 12, 2019 (available here in German). The guidance document specifically addresses issues such as the use of e-mail and IT systems by employees, urine drug tests, personal data collected … Continue Reading
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