Datainspektionen - DI-2019-13112
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| Datainspektionen - DI-2019-13112 | |
|---|---|
 | |
| Authority: | Datainspektionen (Sweden) |
| Jurisdiction: | Sweden |
| Relevant Law: | 5 kap. 6 § |
| Type: | Investigation |
| Outcome: | Other Outcome |
| Started: | |
| Decided: | 17.12.2020 |
| Published: | 15.01.2021 |
| Fine: | None |
| Parties: | Swedish Custom (Tullverket) Swedish Customs (Tullverket) |
| National Case Number/Name: | DI-2019-13112 |
| European Case Law Identifier: | n/a |
| Appeal: | n/a |
| Original Language(s): | Swedish |
| Original Source: | Swedish DPA (in SV) |
| Initial Contributor: | Rie Aleksandra Walle |
The Swedish DPA (Integritetsskyddsmyndigheten) audited Swedish Customs' personal data breaches routines. No serious violations were found, however the DPA gave several recommendations as per the Swedish Criminal Data Act (the "GDPR" for Swedish law enforcement agencies).
English Summary
Facts
On their own initiative and as part of their mandate as a supervisory authority, the Swedish DPA (Integritetsskyddsmyndigheten) conducted an audit of seven law enforcement agencies in Sweden: the Police Authority, the National Economic Crimes Bureau, Customs, the Tax Agency, the Coast Guard, the Prison and Probation Service and the Prosecution Authority.
The audit concerned the law enforcement agencies' policies and procedures for personal data breaches, specifically related to: 1) Ability to detect and manage breaches 2) Documenting breaches 3) Staff training
The audit was conducted as per the Criminal Data Act; the privacy and data protection law in Sweden for law enforcement agencies, which is based on the same principles as the GDPR.
Dispute
Do Swedish Customs have sufficient policies and procedures in place to detect, manage and document personal data breaches, as well as sufficient staff training routines?
Holding
No serious violations were found, however the DPA gave several (similar) recommendations as per the Swedish Criminal Data Act to all agencies.
The Swedish Customs received the following recommendations: 1) To regularly evaluate the effectiveness of the security measures around detecting personal data breaches and regularly revise these in order to maintain adequate protection of personal data. 2) To review their policies around technical logging and following up on these to detect any discrepancies in systems. Update the policy as per the current legal regime. 3) Prepare a common document with all written guidelines/routines related to personal data breaches. 4) Regularly control that the policy for managing breaches are adhered to. 5) Specify in the policy document which information must be documented in a breach and regularly check that this is done correctly. 6) Provide its employees with continuous information and recurring training.
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English Machine Translation of the Decision
The decision below is a machine translation of the Swedish original. Please refer to the Swedish original for more details.
Decision Diary No. 1 (15)
2020-12-17 DI-2019-13112
Ert diarienr
VER 2019-3463
The Swedish Customs
Box 12854
112 98 Stockholm
Supervision according to the Criminal Data Act (2018: 1177) -
The Swedish Customs' routines for handling
personal data incidents
Table of Contents
The Data Inspectorate's decision ................................................ ..................................... 2
Report on the supervisory matter ............................................... .............................. 3
Applicable provisions ................................................ .................................... 4
Grounds for the decision ............................................... ........................................... 6
The Data Inspectorate's review ................................................ ......................... 6
Procedures for detecting personal data incidents ........................................ 7
The Data Inspectorate's assessment ................................................ .................... 8
Routines for handling personal data incidents ....................................... 9
The Data Inspectorate's assessment ................................................ ................... 10
Procedures for documentation of personal data incidents ............................. 11
The Data Inspectorate's assessment ................................................ .................... 11
Information and training on personal data incidents ....................... 12
The Data Inspectorate's assessment ................................................ ................... 13
How to appeal............................................... .............................................. 15
Postal address: Box 8114, 104 20 Stockholm E-mail: datainspektionen@datainspektionen.se
Website: www.datainspektionen.se Phone: 08-657 61 00Datainspektionen DI-2019-13112 2 (15)
The Data Inspectorate's decision
The Data Inspectorate announces the following recommendations with the support of ch.
Section 6 of the Criminal Data Act (2018: 1177):
1. The Swedish Customs should regularly evaluate the effectiveness of those taken
security measures to detect personal data incidents and
revise these as necessary to maintain adequate protection of
personal data.
2. The Swedish Customs should review the authority's routines for logging and
log follow-up and update these in accordance with current
criminal law.
3. The Swedish Customs should draw up a single document with written guidelines
or routines for handling personal data incidents.
4. The Swedish Customs should regularly check the procedures for handling
personal data incidents are followed.
5. The Swedish Customs should in the authority's routines for handling
personal data incidents specify which data of a occurred
incident to be documented and regularly check that
the procedures for documentation of personal data incidents are followed.
6. The Swedish Customs should provide its employees with ongoing information and
recurring training in the handling of personal data incidents
and on the reporting obligation.
The Data Inspectorate closes the case. The Data Inspectorate DI-2019-13112 3 (15)
Report on the supervisory matter
The obligation for the personal data controller - ie. private and public
actors - to report certain personal data incidents to the Data Inspectorate
was introduced on 25 May 2018 by the Data Protection Regulation (GDPR). 1
A corresponding notification obligation was introduced on 1 August 2018 in
the Criminal Data Act (BDL) for so-called competent authorities. The obligation to
report personal data incidents (hereinafter referred to as incidents) aims to strengthen
privacy protection by the Data Inspectorate receiving information about
the incident and may choose to take action when the inspectorate deems it necessary
is needed for the personal data controller to handle the incident on one
satisfactorily and take steps to prevent something similar
occurs again.
A personal data incident is according to ch. § 6 BDL a security incident that
leads to accidental or unlawful destruction, loss or alteration; or
unauthorized disclosure of or unauthorized access to personal data. IN
the preparatory work for the law states that it is usually a question of an unplanned
event that adversely affects the security of personal data
and which have serious consequences for the protection of data. And 3
personal data incident may, for example, be that personal data has been sent
to the wrong recipient, that access to the personal data has been lost, that
computer equipment that stores personal data has been lost or stolen, that
someone inside or outside the organization takes part in information like that
lacks authority to.
A personal data incident that is not dealt with quickly and appropriately can
entail risks to the data subject's rights or freedoms. An incident can
lead to physical, material or intangible damage through, for example
1
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016
on the protection of individuals with regard to the processing of personal data and on that
free flow of such data and repealing Directive 95/46 / EC (General
Data Protection Regulation).
2 A competent authority is in accordance with ch. § 6 BDL an authority that deals
personal data for the purpose of preventing, deterring or detecting criminal activities, investigating
or prosecute crimes, enforce criminal penalties or maintain public order; and
security.
3 Prop.2017 / 18: 232 p. 438Datainspektionen DI-2019-13112 4 (15)
discrimination, identity theft, identity fraud, damage to reputation,
financial loss and breach of confidentiality or secrecy.
There can be many reasons why a personal data incident occurs. Of
The Swedish Data Inspectorate's report series Reported personal data incidents under
The period May 2018 - December 2019 shows that the most common causes
behind the reported incidents were i.a. the human factor, technical errors,
antagonistic attacks and shortcomings in organizational routines or processes. 4
The Data Inspectorate has initiated this supervisory case against the Swedish Customs with the aim of
check if the authority has procedures in place to detect
personal data incidents and whether the authority has and has had routines for
to handle personal data incidents according to the Criminal Data Act (BDL). IN
the review also includes checking whether the Swedish Customs has routines for
documentation of incidents that meet the requirements of
the Criminal Data Ordinance (BDF) and whether the authority has implemented
information and training initiatives on personal data incidents.
The inspection began with a letter to the Swedish Customs on 4 December 2019 and
was followed up with a request for supplementation on 4 March 2020
response to the supervisory letter was received on 17 January 2020 and the supplement
received on March 19, 2020.
Applicable regulations
According to ch. 3, the person responsible for personal data must § 2 BDL, by appropriate
technical and organizational measures, ensure and be able to demonstrate that
the processing of personal data is in accordance with the constitution and that it
data subjects' rights are protected. This means that competent authorities,
Using these measures, should not just ensure that
the data protection regulations are followed but must also be able to show that this is the case. Which
technical and organizational measures required to protect
personal data is regulated in ch. 8 § BDL.
4See the Swedish Data Inspectorate's report series on Reported Personal Data Incidents 2018
(Datainspektionens rapport 2019: 1) p 7 f; Reported personal data incidents January-
September 2019 (Datainspektionen's report 2019: 3) p.10 f. and Reported
personal data incidents 2019 (Datainspektionens rapport 2020: 2) p. 12 f.Datainspektionen DI-2019-13112 5 (15)
In the preparatory work for the law, it is stated that organizational measures referred to in section 2 are
i.a. to have internal strategies for data protection, to inform and educate
staff and to ensure a clear division of responsibilities. Measures such as
taken to show that the treatment is in accordance with the constitution, e.g. be
documentation of IT systems, treatments and measures taken and
technical traceability through logging and log monitoring. What measures
to be taken may be decided after an assessment in each individual case. The measures shall
reviewed and updated as needed. The measures it
personal data controller shall take in accordance with this provision shall in accordance with ch.
§ 1 BDF be reasonable taking into account the nature, scope of treatment,
context and purpose and the specific risks of the treatment.
Of ch. 3 Section 8 of the BDL states that the person responsible for personal data must take
appropriate technical and organizational measures to protect them
personal data processed, in particular against unauthorized or unauthorized use
treatment and against loss, destruction or other unintentional damage. IN
The preparatory work for the Criminal Data Act states that security must include
access protection for equipment, control of data media, storage control,
user control, access control, communication control, input control,
transport control, restoration, reliability and data integrity. This
enumeration, however, is not exhaustive. As an example of organizational
security measures include the establishment of a security policy,
security controls and follow-up, computer security training and
information on the importance of following current safety procedures. Routines for
reporting and follow-up of personal data incidents also constitute such
6
measures.
What circumstances should be taken into account in order to achieve an appropriate level of protection
is regulated in ch. 11 § BDF. The measures must achieve a level of safety
appropriate taking into account the technical possibilities, the costs of
the measures, the nature, scope, context and purpose of the treatment, and
the specific risks of treatment. Special consideration should be given in which
the extent to which sensitive personal data is processed and how sensitive to privacy
other personal data that is processed is. Violation of provisions of
5
Prop. 2017/18: 232 pp. 453
6Prop. 2017/18: 232 pp. 457
7Prop. 2017/18: 232 p. 189 f.Datainspektionen DI-2019-13112 6 (15)
Chapter 3 2 and 8 §§ BDL can lead to penalty fees according to ch. 1 § 2 BDL.
According to ch. 3, the person responsible for personal data must § 14 BDF document all
personal data incidents. The documentation must report the circumstances
about the incident, its effects and the measures taken as a result
of that. The person responsible for personal data must document all that occurred
incidents regardless of whether it must be reported to the Data Inspectorate or not. 8
The documentation must enable the supervisory authority to:
check compliance with the provision in question. Failure to
documenting personal data incidents can lead to penalty fees
according to ch. 6 1 § BDL.
A personal data incident must also, according to ch. § 9 BDL, notified to
The Data Inspectorate no later than 72 hours after the person responsible for personal data
become aware of the incident. A report does not need to be made if it is
it is unlikely that the incident has or will entail any risk
for undue invasion of the data subject's privacy. Of ch. 3 § 10
BDL states that the person responsible for personal data must in certain cases inform it
registered affected by the incident. Failure to report one
personal data incident to the Data Inspectorate can lead to administrative
sanction fees according to ch. 6 1 § BDL. 9
Grounds for the decision
The Data Inspectorate's review
In this supervisory matter, the Data Inspectorate has to take a position on the Swedish Customs
has documented procedures for detecting personal data incidents according to
the Criminal Data Act and whether the authority has and has had routines for dealing with it
incidents since the BDL came into force. The review also includes the question of
compliance with the requirement for documentation of incidents in ch. 14 § BDF
In addition, the Data Inspectorate must decide whether the Swedish Customs has implemented
information and training initiatives for their employees with a focus on
handling of personal data incidents according to BDL.
8 Prop. 2017/18: 232 pp. 198
9 Liability for violations is strict. Thus, neither intent nor negligence is required to
it must be possible to charge a penalty fee, see bill. 2017/18: 232 p. 481.Datainspektionen DI-2019-13112 7 (15)
The review does not include the content of the routines or training efforts
but is focused on verifying that the reviewing authority has
routines on site and that it has implemented training initiatives for
employees regarding personal data incidents. The review includes
however, if the authority's routines contain instructions to document them
information required by the Criminal Data Regulation.
Routines for detecting personal data incidents
The personal data that competent authorities handle within the framework of their
law enforcement and crime investigation activities are to a large extent of
sensitive and privacy sensitive nature. The nature of the business is high
requirements on the ability of law enforcement agencies to protect them
information was registered through necessary protection measures to e.g.
prevent an incident from occurring.
The obligation to report personal data incidents according to ch. 9 § BDL
shall be construed in the light of the general requirements to take appropriate technical and
organizational measures, to ensure appropriate security for
personal data, which is prescribed in ch. 2 and 8 §§. An ability to fast
Detecting and reporting an incident is a key factor. Because they
law enforcement agencies must be able to live up to
the reporting requirement, they must have internal routines and technical capabilities for
to detect an incident.
Based on the needs of the business and with the support of risk and vulnerability analyzes
competent authorities can identify the areas where there is a greater risk
that an incident may occur. Based on the analyzes, the authorities can then
use various instruments to detect a security threat. These can be
both technical and organizational measures. The starting point is that they
the safety measures taken must provide adequate protection and that incidents do not
should occur.
Examples of technical measures include intrusion detectors as automatic
analyzes and detects data breaches and the use of
log analysis tool to detect unauthorized access
(log deviations). An increased insight into the business' "normal" network
traffic patterns help identify things that deviate from the normal
the traffic picture vis-à-vis, for example, servers, applications or data files.Data Inspectorate DI-2019-13112 8 (15)
Organizational measures can, for example, be the adoption of internal strategies
for data protection relating to internal rules, guidelines, routines and different types of
control documents and policy documents. Guidelines and rules for handling
11
personal data, routines for incident management and log follow-up constitute
examples of such strategies. Periodic follow-up of assigned
authorizations is another example of organizational measures. In a competent
authority, there shall be procedures for allocation, change, removal and
regular verification of authorizations. Information for and training of
personnel if the rules and routines for incident management to be followed are
also examples of such measures.
The Data Inspectorate's assessment
The Swedish Customs has mainly stated the following. The authority has detailed
routines and guidelines for following up the processing of personal data in
The Swedish Customs' IT system for law enforcement activities. Through
logging and systematic log follow-up, the Swedish Customs can detect unauthorized persons
activity in their IT systems. Information is available on the authority's intranet
i.a. security logging and how the security logging is followed up
to. In the Swedish Customs' supplementary answer, reference is made to the authority's internal
rule on follow-up of processing of personal data in the Swedish Customs' IT system
for law enforcement activities (STY 2015-99) and to the authority
supporting document for Guidance on follow-up of treatment of
personal data in the Swedish Customs' IT system for law enforcement activities
(VER 2015-489) submitted. It also appears that technical solutions for
to counteract and detect IT and information security incidents,
including personal data incidents, is protection against malicious code on clients
(servers and work computers), next-generation firewalls to detect
network threats and SIEM solution for analyzing network and IT threats
system.
10 Criminal Data Act - Partial report of the Inquiry into the 2016 Data Protection Directive Stockholm
2017, SOU 2017: 29 pp. 302
11 Competent authorities must ensure that there are routines for log follow-up, see Bill.
2017/18: 232 pp. 455 f.
12
Chapter 3 § 6 BDL and supplementary provisions in ch. 6 § BDF
13 A SIEM solution collects log data from the network, extracts meaningful information from
the logs, compare different events to detect attack patterns and help search
log data for causal analysis, which provides an in-depth insight into what is happening in the network. Data Inspectorate DI-2019-13112 9 (15)
With regard to mobile phones, these are handled by security programs that comply
The Swedish Customs' requirements for handling information of high protection value.
Security programs can, for example, identify harmful behaviors on
mobile phones such as improper access to data and taking various actions
depending on the dignity of the error. Examples of measures can be lockout
from internal applications, selective deletion of internal data or
factory reset. Regarding organizational measures, the Swedish Customs refers
to the authority's governing document STY 2019-273, Internal rule for
operational protection, in which i.a. states that if a service card or IT
equipment has been lost or has been used by someone else, this must be reported
urgently to IT support. After that, the IT security function should be immediate
informed. The investigation shows that the Swedish Customs has carried out training
and information efforts. All employees must undergo a mandatory
online introductory course on personal data processing which includes
information on personal data incidents and on reporting obligations.
The Data Inspectorate can state that the Swedish Customs has routines for detecting
personal data incidents on site. The Data Inspectorate notes, however, that they
documents regarding logging and log follow-up that the Swedish Customs refers
to, i.e. the authority's intranet, STY 2015-99 and VER 2015-489, is based on
the Personal Data Act (1998: 204) and has not been updated in accordance with current law
data protection legislation for law enforcement activities. The Data Inspectorate
considers that this justifies a review of these procedures.
The Data Inspectorate therefore recommends, with the support of ch. § 6 BDL, att
The Swedish Customs reviews the authority's routines for logging and log follow-up
and updates these in accordance with applicable data protection laws for
law enforcement activities.
The obligation to take security measures to detect
personal data incidents are not linked to a specific time but the measures
shall be continuously reviewed and, if necessary, changed. For the Swedish Customs to
be able to maintain an adequate level of protection of personal data over time
recommends the Data Inspectorate, with the support of ch. § 6 BDL, att
the authority regularly evaluates the effectiveness of those taken
security measures to detect personal data incidents and that
the authority, if necessary, updates these.Data Inspectorate DI-2019-13112 1 0 (15)
Routines for handling personal data incidents
In order to be able to live up to the requirements for organizational measures in ch. § 8
BDL, the person responsible for personal data must have documented internal routines such as
describes the process to be followed when an incident has been detected or
occurred, including how the incident is to be limited, managed and restored,
and how the risk assessment is to be carried out and how the incident is to be reported internally
and to the Data Inspectorate. The routines must state, among other things: what a
personal data incident is / can be, when an incident needs to be reported, and
to whom, what is to be documented, the division of responsibilities and which
information that should be provided in the context of notification to
The Data Inspectorate.
The Data Inspectorate's control of routines for handling
personal data incidents refer to the time from the entry into force of the Criminal Data Act
i.e. on August 1, 2018.
The Data Inspectorate's assessment
The Swedish Customs has i.a. stated the following. The authority has routines / guidelines for
to report personal data incidents and information on this can be found at
the authority's intranet. Information on the intranet shows that
personal data incidents are categorized as one
information security incident which must be reported to IT support for
assessment and further handling. The Swedish Customs has also submitted
the authority's temporary routine for handling personal data incidents
dated 2019-04-29 and a description of how IT support should register
reported personal data incidents. In the Swedish Customs' supplementary answer
the authority has clarified that similar temporary routines for handling
personal data incidents were in place already in April 2018 and that these
was updated in April 2019. Any further update of the routines has
has not happened since. The Swedish Customs also states that there is nothing
produced control documents that specifically address personal data incidents
and refers to the authority's governing document STY 2019-785 which contains
a routine for handling information and IT security-related incidents
and problems. In cases where personal data is affected in an incident shall
the incident according to the control document is reported via IT support.
Taking into account the documents submitted and what has emerged in
the case, the Data Inspectorate initially states that the Swedish Customs from
the time when the Criminal Data Act came into force has had and has routines for the Data Inspectorate DI-2019-13112 1 1 (15)
handle personal data incidents on site. Of the review, however, it has
it has emerged that the Swedish Customs' routines are found in various documents and contain
different parts of the routines. For example, the Swedish Customs' intranet shows
information about what a personal data incident is and how an incident should be
reported and in the authority's temporary routines for handling
personal data incidents, you can read about the division of responsibilities and
the process for handling personal data incidents. The Data Inspectorate
also notes that the Swedish Customs does not have a produced control document
specifically for handling personal data incidents. It can according to
The Data Inspectorate's opinion entails a problem with disseminated information
and risk of slow incident management.
The Data Inspectorate therefore recommends, with the support of ch. § 6 BDL, att
The Swedish Customs prepares a single document with written guidelines or
routines for handling personal data incidents.
To be able to handle discovered personal data incidents in a correct way
and counteract its effects and risks on the data subjects' personalities
Integrity is important. The Data Inspectorate therefore recommends, with the support of
Chapter 5 § 6 BDL, that the Swedish Customs regularly checks that the routines for
handling of personal data incidents is followed.
Routines for documentation of personal data incidents
A prerequisite for the Data Inspectorate to be able to check
compliance with the documentation requirement of incidents in ch. § 14 BDF is that
the documentation includes certain information that should always be included.
The documentation shall include all details of the incident, including its
reasons, what happened and the personal data concerned. It should too
contain the consequences of the incident and the corrective actions taken
personal data controller.
The Data Inspectorate's assessment
The Swedish Customs has mainly stated the following. A case, such as one
personal data incident, documented in JIRA Service desk. The report on
the investigation of personal data incident is saved. External communication with
The data inspection is saved in the diary during the diary series VER. By the authority
intranet states that the Swedish Customs must document everyone
personal data incidents and at the same time a description of which appears
information and circumstances of a personal data incident such as the Data Inspectorate DI-2019-13112 1 2 (15)
the documentation shall include. The Swedish Customs has also produced a template for
reporting and investigation of personal data incidents where one appears
detailed description of an incident that occurred and what to do
documented. The template is intended to serve as a support in the investigation
and as an internal documentation when the investigation is completed.
The Data Inspectorate states that the Swedish Customs has an internal IT system to
i.a. report incidents involving personal data. In addition, it appears from
the authority's intranet that all personal data incidents must be documented
and what information the documentation must include. In addition,
the authority has produced a template for reporting and investigation of
personal data incidents that meet the requirements of the person in question
the provision. The Data Inspectorate notes, however, that the Swedish Customs' routines for
handling of personal data incidents lacks a description of which
information to be covered by the documentation.
To be able to document occurred personal data incidents correctly
and thereby counteract the risk of the documentation becoming deficient or
incomplete is important. Inadequate documentation can lead to
incidents are not handled and remedied properly, which can get
impact on privacy. The Data Inspectorate therefore recommends,
with the support of ch. 5 § 6 BDL, that the Swedish Customs' routines for handling
personal data incidents are supplemented with a description of which data
of an incident that is to be documented. In addition, the Swedish Customs should
carry out regular checks on the internal documentation of
personal data incidents
Information and training on personal data incidents
The staff is an important resource in the security work. It's not just enough
internal procedures, rules or governing documents if users do not follow them.
All users must understand that the handling of personal data must take place in one go
legally secure and that it is more serious not to report an incident than
to report e.g. a mistake or a mistake. It is therefore required that everyone
users receive adequate training and clear information on data protection.
The person responsible for personal data must inform and train his staff in matters
on data protection including the handling of personal data incidents. Of
The Data Inspectorate's report series Reported Personal Data Incidents under
the period 2018-2019 it appears that the human factor constitutes the most commonData Inspectorate DI-2019-13112 1 3 (15)
14
the cause of reported personal data incidents. These mainly consist of
individuals who, consciously or unconsciously, do not follow internal routines
processing of personal data or made a mistake in handling
personal data. About half of the incidents are due to it
The human factor is about misplaced letters and emails.
In the opinion of the Data Inspectorate, this underlines the importance of
internal routines and technical safety measures need to be supplemented with
ongoing training, information and other measures to increase knowledge and
awareness among employees.
The Data Inspectorate's assessment
On the question of how information and education about incidents is provided
employees, the Swedish Customs has stated i.a. following. The Swedish Customs uses the tool
Teacher platform where employees can complete online courses. All
employees must undergo a mandatory online introductory course on
personal data processing. The course component includes, among other things, training on
what constitutes a personal data incident and how it should be reported
internally. Information on what constitutes personal data incidents and on
the importance of reporting these is also part of it
basic training undergone by customs graduates in law enforcement.
Furthermore, the Swedish Customs has plans for further information efforts that will
be aimed at specific areas of activity.
In the light of what appears from the investigation, the Data Inspectorate considers
that the Swedish Customs has shown that the authority has provided information and training
on handling personal data incidents to their employees.
To maintain competence and ensure that new staff receive
education, recurring information and education is important
the employees and hired staff. The Data Inspectorate recommends, with
support of ch. 5 § 6 BDL, that the Swedish Customs provides the employees with ongoing information
and recurring training in the handling of personal data incidents
and the obligation to report these.
14
Report 2019: 1, report 2019: 3 and report 2020: 2. MSB has drawn similar conclusions
its annual report for serious IT incidents, ie. that most of the incidents are due
human mistakes, see https://www.msb.se/sv/aktuellt/nyheter/2020/april/arsrapporten-for-
serious-it-incidents-2019-ar-slappt / Datainspektionen DI-2019-13112 1 4 (15)
This decision was made by unit manager Charlotte Waller Dahlberg after
presentation by lawyer Maria Angelica Westerberg. At the final
The handling of the case also has the IT security specialist Ulrika
Sundling and the lawyer Jonas Agnvall participated.
Charlotte Waller Dahlberg, 2020-12-17 (This is an electronic signature)
Copy for knowledge of:
The Swedish Customs' data protection representativeData Inspectorate DI-2019-13112 1 5 (15)
How to appeal
If you want to appeal the decision, you must write to the Data Inspectorate. Enter i
the letter which decision you are appealing and the change you are requesting.
The appeal must have been received by the Data Inspectorate no later than three weeks from
on the day the decision was announced. If the appeal has been received in due time
the Data Inspectorate forwards it to the Administrative Court in Stockholm
examination.
You can e-mail the appeal to the Data Inspectorate if it does not contain
any privacy-sensitive personal data or data that may be covered by
secrecy. The authority's contact information appears on the first page of the decision.
