In recent months, the European Court of Justice (“CJEU”) issued five judgments providing some clarity on the scope of individuals’ rights to claim compensation for “material and non-material damage” under Article 82 of the GDPR. These rulings will inform companies’ exposure to compensation claims, particularly in the context of the EU’s Collective Redress Directive, but open questions remain about the quantum of compensation courts will offer in these cases and we expect both the CJEU and national courts to deliver additional case-law clarifying this topic in the coming year (for more information on recent CJEU cases related to compensation, see our previous blog posts here and here).
- In VB v Natsionalna agentsia za prihodite (C-340/21), the CJEU concluded that individuals may have suffered “non-material damage”—and therefore be able to claim compensation—if they can demonstrate that they feared future misuse of personal data that was compromised in a personal data breach.
- In VX v Gemeinde Ummendorf (C-456/22), the CJEU found that there is no de minimis threshold for damage, below which individuals cannot claim for compensation.
- In BL v MediaMarktSaturn (C-687-21), the CJEU restated its existing case-law, and expanded upon its analysis in VB by clarifying that alleged harms cannot be “purely hypothetical”.
- In Kočner v Europol (C-755/21), the CJEU awarded non-material damages of €2000 for the publication in newspapers of transcripts of “intimate” text messages.
- In GP v Juris GmbH (C-741/21), the CJEU found that where one processing activity infringes multiple provisions of the GDPR, this should not allow claimants to “double-count” the harm they suffered.
We provide further detail on each case below.Continue Reading Rounding up Five Recent CJEU Cases on GDPR Compensation