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connection with Article 5 paragraph 1 point c, Article 9 paragraph 1, Article 58 paragraph 2 point f, point g and point i and with Article 83 paragraph 2 and 3,

imposed a fine of €10000 aggravated by article 83(2)(b) GDPR (intentional or negligent character of the infringement) and article 83(2)(k) GDPR in relation

the processing (Article 21(1) GDPR). Finally, the DPA fined the controller €12,000 for a violation of Article 6(1) GDPR due to the lack of a valid legal basis

consent under Article 6(4) GDPR and further processing for a compatible purpose under Article 6(4) GDPR. See the commentary on Article 6(4) GDPR for details

of Laws of 2019, item 1781) and Article 57(1)(a), Article 83(1)-(2) and Article 83(6) in connection with Article 58(2)(e) and (i) of the Regulation of

against the controller. Based on Article 72(1)(b) of the national data protection law, and Articles 83(1) and 83(2) GDPR, the DPA considered aggravating

regarding the violation of Article 15(1)(b) and (c). In accordance with Article 58(2) and Article 83(2), the DPA fined Company A €1,500. Since the company

relation to Article 6(1)(a) GDPR since the consent could not be considered valid. Finally, the DPA applied two aggravating circumstances of Article 83(2) GDPR:

1 lit. a), art. 58 sec. 2 lit. i), art. 83 sec. 1-3 and art. 83 sec. 4 lit. a) in connection with art. 33 paragraph. 1 and art. 34 sec. 1 and 2 of the

2 of the GDPR, and with the provisions of article 76 of the LOPDGDD, with respect to section k) of the aforementioned article 83.2 GDPR. Article 83.2 of

states that the party concerned violated Article 83(4)(a) GDPR in conjunction with [Article 32(1) GDPR. Article 32 (1) GDPRby failing, at least with gross

required under the GDPR (e.g. from a security perspective under Article 32 GDPR or as a means of data minimisation under Article 5(1)(c) GDPR) can get confused

referred to in Article 83(2) of the RGPD, with with regard to the infringement committed in breach of the provisions of Article 13 thereof allows set a penalty

health of a large number of data subjects, i.e. all the patients of the Company itself (Article 4(1), no. 15 of the Regulation and Article 83(2)(a) and (g)

analyzes the criteria by Article 83.2 of the GDPR: - As to the nature and seriousness of the violation [article 83.2 a) of the GDPR], with regard to breaches

of personal data under Article 9(1) GDPR, explicit consent (Article 9(2)(a) GDPR) would have been necessary for part of the processing operations. In addition

for detecting information on the health of a few hundred data subjects (Article 83, paragraph 2, letters a) and g) of the Regulation); from the point of

negligent action (Article 83(2)(b) GDPR) and that basic identifiers such as name, surname, and address are affected (Article 83(2)(g) GDPR), including also

for the alleged violation of Article 5.1.f) of the GDPR and Article 32 of the GDPR, typified in Article 83.5 of the GDPR. FIFTH: Notified of the aforementioned

SOLUCIONES ENERGÉTICAS, S.A., with NIF A85818797, for a violation of Article 6.1 of the GDPR, typified in Article 83.5 of the GDPR, a fine of 50,000 euros (fifty