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provisions of Article 64 of Law 39/2015 of 1 October on the Common Administrative Procedure for Public Administrations, which in its paragraph (f) provides that

days computed from the day following the of the notification. Article 64.2.f) LPACAP - provision of which the claimed party was informed in the agreement

be considered as a motion for resolution, as set out in the Article 64(2)(f) LPACAP. The procedure shall last a maximum of nine months from the date of

agreement to initiate the procedure. In this sense, the article 64.2.f) of the LPACAP - provision of which the complainant was informed in the agreement

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

the same. Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common for Public Administrations (hereinafter LPACAP) -provision of which

in the article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

requirements provided for in articles 64.2 and 68 LPACAP. It cannot be ignored either that article 85 of the LPACAP -which contemplates the possibility of

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP - provision of which the respondent was informed in the agreement

regarding it. Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common Public Administrations (hereinafter LPACAP) - provision of which

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), being carried out by means of publication in the edictal notice board

sedeagpd.gob.es 2/12 in accordance with the provisions of articles 63 and 64 of the LPACAP, for the alleged violation of Article 5.1.c) of the RGPD, typified

63 and 64 of Law 39/2015, of October 1, 2011, on the Common Administrative Procedure of Public Administrations (hereinafter referred to as LPACAP), for

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), was collected on 12/23/2021 as stated in the acknowledgment of receipt

Common Administrative Procedure of Administrations Public (hereinafter, LPACAP), was collected on 10/06/2021 as stated in the acknowledgment of receipt

heading of this document. Furthermore, in accordance with Articles 64(2)(f) and 85 of the LPACAP, it is informs that, if he does not make representations within

established in Article 64.2.f) of Law 39/2015 of 1 October on the Common Administrative Procedure of Public Administrations (hereinafter LPACAP). In accordance

that he could access the content of the same voluntarily. Article 64.2.f) of the LPACAP - provision of which the respondent was informed in the agreement

claimed party. Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common Public Administrations (hereinafter LPACAP) -provision of which

38(4)(d) of that rule. NAME: instructor to D. E.E.E. and, as secretary, to Dª F.F.F., indicating that any of them may be challenged, where appropriate, in accordance

in the Article 64.2.f) of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations (hereinafter, LPACAP). In accordance

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

claimed party. Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common Public Administrations (hereinafter LPACAP) -provision of which

sedeagpd.gob.es 9/11 64.2(f) of Law 39/2015 of 1 October on the Common Administrative Procedure of the Public Administration (hereinafter LPACAP). In accordance

has been no received any allegation by the claimed party. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

established in Article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

In Consequently, on April 2, 2023, for the purposes set forth in article 64.1 of the LOPDGDD, the Director of the Spanish Data Protection Agency agreed

Article 5.1.f) of the GDPR Article 5.1.f) “Principles relating to processing” of the GDPR establishes: "1. The personal data will be: (…) f) treated in

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

article section 85 of the LPACAP. In consideration of the foregoing and in accordance with the provisions of article 64.2.f) of the LPACAP, the agreement to initiate

in theArticle 64.2.f) of Law 39/2015, of October 1, of the Administrative ProcedureCommon of Public Administrations (hereinafter, LPACAP).C / Jorge Juan

may be considered a resolution proposal, as established in article 64.2.f) of the LPACAP. The procedure will have a maximum duration of nine months from the

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

Consequently, dated August 19, 2021, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

in the Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations (hereinafter, LPACAP). In accordance

out in the Article 64.2.f) of Law 39/2015 of 1 October on Administrative Procedure Commonwealth of Independent States (hereinafter LPACAP). In accordance

gob.es 11/13 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of the Public Administrations (in hereinafter, LPACAP), for the alleged

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

resolution, as established in article 64.2.f) of Law 39/2015, of the LPACAP. In accordance with Article 85.1 of LPACAP, if the sanction to be imposed is a

the claimed party, in accordance with the provided in articles 63 and 64 of the LPACAP, for the alleged violation of article 6 of the GDPR, typified in article

proposal, as established in article 64.2.f) of the LPACAP. In accordance with the provisions of article 85 of the LPACAP, in the event that the penalty to

in the article64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure ofPublic Administrations (hereinafter, LPACAP).In accordance

proposal, as established in article 64.2.f) of the LPACAP. In accordance with the provisions of article 85 of the LPACAP, in the event that the penalty to

sedeagpd.gob.es 5/7 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

Procedure of Public Administrations (hereinafter te, LPACAP), for the alleged infringement of Article 5.1.f) of the GDPR, typified in the Article 83.5 of the

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

established in article64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure ofthe Public Administrations (hereinafter, LPACAP).In accordance

the top of this document. Likewise, in accordance with articles 64.2.f) and 85 of the LPACAP, you are informed that, if it does not make allegations in time

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

set out in the Article 64.2.f) of Law 39/2015 of 1 October on Administrative Procedure Commonwealth of Independent States (LPACAP). In accordance with Article

out in the Article 64.2.f) of Law 39/2015 of 1 October on Administrative Procedure Commonwealth of Independent States (hereinafter LPACAP). In accordance

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP - provision of which the claimed party was informed in the agreement

verified that no allegation has been received some by the DGP. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

of the foregoing and in accordance with the provisions of article 64.2.f) of the LPACAP, the agreement to initiate PS / 00227/2020 is considered Pro- Resolution

Determining the amount of the penalty is an obligation imposed by article 64.2 of the LPACAP and then point out that “not only are the requirements mentioned,

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

out in Article 64.2(f) of Law 39/2015 of 1 October on the Common Administrative Procedure of the Public Administration (hereinafter LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

2/7 with articles 64.2.f) and 85 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations (LPACAP), by not carrying

in the Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations (hereinafter, LPACAP). In accordance

in the article64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of thePublic Administrations (hereinafter, LPACAP).C / Jorge Juan

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

Article 64 of Law 39/2015, of 1 October, on the Common Administrative Procedure of Public Administrations, are applicable, which in section f) establishes

Consequently, dated June 17, 2021, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of the Public Administrations (in hereinafter, LPACAP), for the alleged

established in article64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure ofthe Public Administrations (hereinafter, LPACAP).C / Jorge Juan

as set out in Article 64.2.f) of Law 39/2015, of 1 October, on the Common Administrative Procedure of Public Administration (LPACAP). In accordance with

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

Page 11 11/14 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

for in Article 64(2)(f) of Law 39/2015 of 1 October on the Common Administrative Procedure of the Public Administration (hereinafter LPACAP). In accordance

proposal of resolution, according to the established in the article 64.2.f) of the LPACAP. The sanctioning procedure will have a maximum duration of nine months

this sense, article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (LPACAP) - provision of which

Article 64(2)(f) of the C/ Jorge Juan, 6 www.aepd.es 28001 - Madrid sedeagpd.gob.es 14/16 LPACAP. In accordance with Article 85 of the LPACAP, if the sanction

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

article 5.1.f) of the GDPR. V Classification of the infringement of article 5.1.f) of the GDPR The aforementioned infringement of article 5.1.f) of the GDPR

in the article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

considered a proposal for resolution, as established in Article 64.2.f) of the LPACAP. The sanctioning procedure will have a maximum duration of nine months

articleArticle 64.2.f) of Law 39/2015, of October 1, on the Administrative Procedure Co-common of the Public Administrations (hereinafter, LPACAP).In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

Article 6(1)(f), the legitimate interests of the controller or of a third party; and (d) where the processing is based on Article 6(1)(f), the legitimate

in the article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

claimed party. Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common Public Administrations (hereinafter LPACAP) -provision of which

in articleass 64.2.f) of Law 39/2015, of October 1, of the Administrative Procedure Co-of the Public Administrations (hereinafter, LPACAP).In accordance

in the Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of 1 October, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

Juan, 6 www.aepd.es 28001 – Madrid sedeagpd.gob.es 10/18 Article 64.2.f) of the LPACAP -provision of which COOLTRA was informed in the agreement to open

established in article64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure ofthe Public Administrations (hereinafter, LPACAP).In accordance

in the Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

alleged infringement of Article 5(1)(f) GDPR. Does the action of the defendant constitute a violation of Article 5(1)(f) GDPR? Considering the evidence available

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

in the article64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure ofPublic Administrations (hereinafter, LPACAP).In accordance

conformity with articles 64.2.f) and 85 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations (LPACAP), by not carrying

the claimed party, in accordance with the provisions of articles 63 and 64 of LPACAP, for the alleged violation of the article 5.1.c) of Regulation (EU) 2016/679

of articles 63 and 64 of Law 39/2015, of October 1, of Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

indicated in Article 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations, which in its section f) establishes

accordance with Articles 64.2.f) and 85 of Law 39/2015 of 1 October on Procedure Common Administration of Public Administration (LPACAP), as it does not allegations

contrary to what the Proposal for a Resol- tion, neither Article 64 nor Article 85 of the LPACAP establishes that in the At the beginning, the specific amount

to the agreement to initiate the sanctioning file, under Article 64.2.f) of the LPACAP, and given that the agreement to initiate the proceedings contained

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

procedure to the claimed, withpursuant to the provisions of articles 63 and 64 of the LPACAP, for the alleged infringementof Article 58.1 of the RGPD, typified

and the lack of cooperation with the Spanish Data Protection Agency (83 (2) (f) GDPR). Therefore, in view of the aggravating factors applied to the case,

Articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

established in article64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure ofthe Public Administrations (hereinafter, LPACAP).In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

established by Article 5(1)(f) GDPR? Was there a personal data breach? The AEPD considered that there was an infringement of Article 5(1)(f), as there was a leak

accordance with Articles 64.2.f) and 85 of Law 39/2015 of 1 October on Procedure Common Administration of Public Administration (LPACAP), as it does not allegations

the provisions of articles 63 and 64 of the C/ Jorge Juan, 6 www.aepd.es 28001 – Madrid sedeaepd.gob.es 4/20 LPACAP, for the alleged violation of Article

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations, which in its section f) establishes that

established in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

provisions of article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its Section f) establishes that

and 64 of Law 39/2015 of 1 October 2015 on the Common Administrative Procedure of the Public Administrations (hereinafter referred to as the LPACAP), on

out in Article 64.2(f) of Law 39/2015 of 1 October on the Common Administrative Procedure of the Public Administration (hereinafter LPACAP). In accordance

of Articles 63 and 64 of Law 39/2015, of 1/10, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged violation

in Article 64 of Law 39/2015 of 1 October on the Procedure Common Administrative Framework for Public Administrations, which in paragraph (f) provides that

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter LPACAP), for the alleged

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

conformity with articles 64.2.f) and 85 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations (LPACAP), by not carrying

63 and 64 of Law 39/2015, of October 1, 2011, on Common Administrative Procedure for Public Administrations (hereinafter referred to as LPACAP), for the

in the article64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure ofPublic Administrations (hereinafter, LPACAP).In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

in accordance with the provisions of the LOPDPGDD, and in addition to the LPACAP, in processing of sanctioning procedures. SECOND: As proven facts of the

no allegation has been received from the claimed party. Article 64.2.f) of the LPACAP - provision of which the claimed party was informed in the agreement

Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP), was collected on 02/14/2022 as stated in the acknowledgment of receipt

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

provisions of article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its Section f) establishes that

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

indicated in the Article 64 of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations, which in its section f) establishes that

recognizes each supervisory authority, and as established in Articles 47, 64.2 and 68.1 of the Organic Law 3/2018, of 5 December, on the Protection of

with articles 64.2.f) and 85 of Law 39/2015, of October 1, on the Procedure Common Administrative Law of Public Administrations (LPACAP), by not carrying

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

63 and 64 of Law 39/2015, of October 1, 2011, on the Common Administrative Procedure of Public Administrations (hereinafter referred to as LPACAP), for

Articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

proceedings against the respondent, with in accordance with Articles 63 and 64 of Law 39/2015 of 1 October on the Common Administrative Procedure for Public

provisions of article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its section f) establishes that

against the claimed party, pursuant to the provisions of articles 63 and 64 of the LPACAP, for the alleged infringement of Article 6.1 of the GDPR, typified

provisions of articles 63 and 64 of Law 39/2015, of October 1, of Common Administrative Procedure of Public Administrations (LPACAP), imposing a penalty of 10

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations, which in its section f) establishes that

Articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure for Public Administrations (hereinafter, LPACAP), for the alleged

provisions of article 64 of Law 39/2015, of October 1,Common Administrative Procedure of Public Administrations, which in itssection f) establishes that in

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

virtue of the powers established in article 58.2 of the RGPD and in articles47, 64.2 and 68.1 of Organic Law 3/2018, of December 5, on Data ProtectionPersonal

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for two violations

Article 64 of Law 39/2015 of 1 October on the Procedure Common Administrative Framework for Public Administrations, which in its paragraph (f) provides

Common Administrative Procedure of the Administrations Public (hereinafter, LPACAP), in terms of processing procedures sanctioners. SECOND: As proven facts

Consequently, dated September 3, 2021, for the purposes provided in its Article 64.2 of the LOPDGDD, the Director of the Spanish Agency for the Protection of

Consequently, dated January 22, 2021, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations, which in its section f) establishes that

Consequently, on April 30, 2022, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

In Consequently, on May 21, 2022, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

Principles regarding treatment, establishes in its letter f) the following: “The personal data will be: (…) f) processed in such a way as to guarantee adequate

satisfied. Consequently, on June 27, 2022, for the purposes set forth in article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

AEPD fined a gas distribution company €12,000 for a violation of Article 5(1)(f) of the GDPR. A customer of a gas distribution company (Madrileña Red De Gas

Data Protection, as laid down in Article 56(2) in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of the European Parliament and of the Council

Mr. F.F.F. on your SIM cards originals that same day, November 14, 2019, leaving the incidence resolved. Thus, as of the date of this claim, Mr. F.F.F.

consequently, dated May 8, 2022, for the purposes provided for in its article 64.2 of the LOPDGDD, the Director of the Spanish Data Protection Agency agreed

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

complaining party. Consequently, for the purposes provided in its Article 64.2 of the LOPDGDD, the Director of the Spanish Agency for the Protection of

applicableindicated in article 64 of Law 39/2015, of October 1, on the ProcedureCommon Administrative of Public Administrations, which in its section f)establishes that

In Consequently, on May 31, 2022, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

the proceedings, the respondent has not submitted The provisions of Article 64 of the Directive apply to this case. Law 39/2015, of 1 October, on the Common

the defendant has not submitted brief of allegations, for which article 64.2.f) of the LPCAP applies, which establishes that in case of not making allegations

applicableindicated in article 64 of Law 39/2015, of October 1, on the ProcedureCommon Administrative of Public Administrations, which in its section f)establishes that

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

the almost total identity between its article 7.f) and article 6.1.f) of the RGPD Article 7, letter f) of said Directive indicated: “Member States shall

Consequently, on April 26, 2022, for the purposes provided in its article 64.2 of the LOPDGDD, the Director of the Spanish Agency for Data Protection agreed

complainant filed a complaint with the AEPD, pursuant to Articles 56 and 57(1)(f) GDPR for obstructing his right of access. Could the data controller require

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

established by Article 5(1)(f) GDPR? Was there a personal data breach? The AEPD considered that there was an infringement of Article 5(1)(f), as there was a leak

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

sectors, each of which has its own legal personality and therefore its own C.I.F. and has not maintained any relationship with the claimant. Results of the

of Articles 63 and 64 of Law 39/2015, of 1/10 of the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP), for the alleged

with the provisions of paragraph 2 of Article 56 in relation to paragraph 1 f) of Article 57, both of Regulation (EU) 2016/679 of the European Parliament

accordance with the provisions of Article 56(2) in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of the European Parliament and of the Council

Protection, as laid down in Article 56(2) in in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of European Parliament and of the Council

specified in the art. 64.2 b) of Law 39/2015, of 1/10, of the Common Administrative Procedure of Public Administrations, (as hereinafter, LPACAP) the corresponding

attributable to SESCAM, for violation of Article 5.1.f) of the RGPD which it states: <<1. The personal data will be: (f) processed in such a way as to ensure appropriate

provisions of article 64 of Law 39/2015, of October 1, of theCommon Administrative Procedure of Public Administrations, which in itsSection f) establishes that

provisions of articles 63 and 64 of Law 39/2015, of October 1, of Common Administrative Procedure of Public Administrations (LPACAP), to impose a penalty of

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

accordance with the provisions of Article 56(2) in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of the European Parliament and of the Council

INTERNACIONAL SYSTEMS, in accordance with the provisions of articles 63 and 64 of the LPACAP, for the alleged violation of article 9 of the GDPR, typified in article

in the article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

Claimant 6.- E / 06305/2020 E.E.E. - *** NIF.4 Claimant 7.- E / 07018/2020 F.F.F. - *** NIF. 5 Claimant 8.- E / 07821/2020 G.G.G. - *** NIF.6 Claimant 9.-

Protection, as laid down in Article 56(2) in in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of European Parliament and of the Council

relationship (by inte- legitimate responsibility of the person in charge, art. 6.1.f GDPR) and keep them for no longer necessary to maintain the end of the treatment

grants each control authority and as established in articles 47, 48.1 and 64.1 of the Law Organic 3/2018, of December 5, Protection of Personal Data and

allegation has been received by UPMOBILE SOLUTIONS, S.L.. Article 64.2.f) of the LPACAP - provision of which UPMOBILE was informed SOLUTIONS, S.L. in the

be considered a proposal of resolution, as established in article 64.2.f) of the LPACAP. This initiation agreement, which was notified to the claimed party

with the provisions of section 2 of article 56 in in relation to paragraph 1 f) of article 57, both of Regulation (EU) 2016/679 of the European Parliament

in the article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common of Public Administrations (hereinafter, LPACAP). In accordance

Jorge Juan, 6 www.aepd.es 28001 – Madrid sedeagpd.gob.es 2/7 Article 64.2.f) of the LPACAP - provision of which the claimed party was informed in the agreement

Article 5.1.f) of the RGPD Article 5.1.f) “Principles related to treatment” of the RGPD establishes: "1. The personal data will be: (…) f) treated in such

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

in the article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP), for the alleged

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

data and postal addresses of the parents of D.D.D .; Mr. E.E.E. and Doña F.F.F .. What about D.D.D. no data is obtained from the itself, and the DNI may

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

Consequently, dated December 18, 2020, for the purposes provided in its Article 64.2 of the LOPDGDD, the Director of the Spanish Agency for the Protection of

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

no allegation has been received from the claimed party. Article 64.2.f) of the LPACAP - provision of which the claimed party was informed in the agreement

gob.es 13/16 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in the Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common to Public Administrations (hereinafter, LPACAP). C/ Jorge Juan

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). C/ Jorge Juan

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

referred to in article 5.1.f) of Regulation (EU) 2016/679. " III Article 5.1.f) of the RGPD establishes that personal data will be: "F) treated in such a way

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). C / Jorge

verified that no allegation has been received from the reclaimed. Article 64.2.f) of LPACAP -which is outlined in the opening agreement of the procedure- establishes

of the foregoing and in accordance with the provisions of article 64.2.f) of the LPACAP, the agreement to initiate PS / 00375/2021 is considered Resolution

accordance with Article 65 of the LOPDGDD and for the purposes set forth in Article 64.2 thereof, on June 12, 2019 the Director of the AEPD agreed to admit the claim

the proceedings, and in accordance with the provisions of Article 64.2.f) of the LPACAP, the aforementioned agreement to initiate the proceeding is resolution

BUT F.3 Would you provide Vodafone with the list of threads involved or who would be involved? in the processing of Vodafone's personal data? BUT F.4 Is

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative Law of Public Administrations, which in its section f) establishes

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

in the article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

no allegation has been received from the party claimed. Article 64.2.f) of the LPACAP -provision of which the claimed party was informed in the agreement

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

sanctioning proceedings were initiated, based on Article 63 and Article 64 LPACAP and an infringement of Article 6(1) GDPR typified in Article 83(5) GDPR

the same Article 64.2.f) of Law 39/2015, of October 1, on Administrative Procedure Common Public Administrations (hereinafter LPACAP) -provision of which

of articles 63 and 64 of Law 39/2015, of October 1, onCommon Administrative Procedure of Public Administrations (hereinafter,LPACAP), for the alleged violation

no allegation has been received by the respondent party. Article 64.2.f) of the LPACAP - provision of which the respondent was informed in the agreement

against EASYJET, in accordance with the provided in articles 63 and 64 of the LPACAP, for the alleged violation of article 15 of the RGPD, typified in article

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of the Public Administrations (in hereinafter, LPACAP), for the alleged

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereafter, LPACAP), for the alleged

provided in article 64.2.b) of the law 39/2015, of October 1, Common Administrative Procedure of the Public Administrations (hereinafter LPACAP), the sanction

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative Law of Public Administrations, which in its section f) establishes

no allegation has been received any by the claimed party. Article 64.2.f) of the LPACAP - provision of which the claimed party was informed in the agreement

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative Law of Public Administrations, which in section f) establishes that

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

established in article 64.2.f) of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP). In accordance

(SSTC 11/1981, of 8 April, F. 7; 196/1987, of 11 December [RTC 1987, 196] , F. 6; and with regard to art. 18, STC 110/1984, F. 5)". In relation to this

accordance with articles 64.2.f) and 85 of Law 39/2015, of October 1, on Common Administrative Procedure of Public Administrations (LPACAP), at the Failure to

data without implementing adequate security measures, violating Article 5(1)f GDPR and Article 32 GDPR. The data subject had health problems arising from

resolution, as established in the article 64.2.f) of the LPACAP. In accordance with the provisions of article 85 of the LPACAP, you may recognize your responsibility

in article 64.2.f) of Law 39/2015, of October 1, on the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP). In accordance

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative Law of Public Administrations, which in section f) establishes that

stated in article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its section f) establishes that

saidrequirements.28 In this regard, article 7, letter f), of Directive 95/46 - (current article 6.1.f) of the RGPD) - fixesthree cumulative requirements for

considered as a Resolution proposal” in the terms Article 64 letter f) Law 39/2015 (October 1). “f) Indication of the right to make allegations and to be

stated in article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its section f) establishes that

articles 63 and 64 of Law 39/2015, of 1 of October, of the Common Administrative Procedure of the Public Administrations (hereinafter, LPACAP), for the alleged

considered as a Resolution proposal” in the terms Article 64 letter f) Law 39/2015 (October 1). “f) Indication of the right to make allegations and to be

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

against EDREAMS, in accordance with the provisions of Articles 63 and 64 of the LPACAP, for the alleged violation of Article 15 of the GDPR, typified in Article

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations, which in its section f) establishes that

consequently, dated July 6, 2022, for the purposes provided for in article 64.2 of the LOPDGDD, the Director of the Spanish Data Protection Agency agreed

specified in the art. 64.2 b) of Law 39/2015, of 1/10, of the Common Administrative Procedure of Public Administrations (LPACAP), the The penalty that

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

article 5.1.f) of the RGPD. VII Classification of the violation of article 5.1.f) of the RGPD The aforementioned violation of article 5.1.f) of the RGPD

article 5.1.f) of the RGPD. VII Classification of the violation of article 5.1.f) of the RGPD The aforementioned violation of article 5.1.f) of the RGPD

C.C.C. (claimant 3), D. DDD (claimant 4); by Dª E.E.E. (claimant 5) by D.F.F.F. (claimant 6), and D. GGG (claimant 7), and based on the following: ACTS

stated in article 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations, which in its section f) establishes that

indicated in article 64 of Law 39/2015, of October 1, on the Procedure Common Administrative of Public Administrations, which in its section f) establishes that

article 5.1.f) of the RGPD. V Classification of the violation of article 5.1.f) of the RPGD The aforementioned violation of article 5.1.f) of the RGPD

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

the Spanish DPA concluded that there was an infringement of Articles 5(1)(f) and 32(1) of the GDPR. The complainant received a notification from Consellería

said action is not would have been carried out in accordance with arts. 5.1.f) and 32 of the GDPR, a request that is denied through Resolution dated 12/24/2021

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of the Public Administrations (in hereinafter, LPACAP), for the alleged

the complained party, with according to the provisions of articles 63 and 64 of Law 39/2015, of October 1, of the Pro- Common Administrative Assignment

SAW Article 5.1. f) GDPR Article 5.1.f) “Principles relating to processing” of the GDPR establishes: "1. The personal data will be: (…) f) treated in such

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the following

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (hereinafter, LPACAP), for the alleged

the claimed party, in accordance with the provided in articles 63 and 64 of the LPACAP, when appreciating reasonable indications of violation of the provisions

articles 63 and 64 of Law 39/2015, of October 1, of the Common Administrative Procedure of Public Administrations (in hereinafter, LPACAP), for the alleged

adjusted to the provisions of article 68 of the LOPDGDD and article 64.2 of the LPACAP (in this case, of the different corrective powers provided for in

Description of the impression provided: . Header: Addressed to GOOGLE LLC by F.F.F., on 01/03/2019, as as a result of a court ruling. C/ Jorge Juan, 6 www.aepd

b) of the aforementioned Regulation. For the purposes specified in the art. 64.2 b) of Law 39/2015, of October 1, on Common Administrative Procedure of Public

a violation of Articles 5(1)(f) and 32 GDPR. Finally, the DPA reprimanded the controller for violations of Articles 5(1)(f) and 32 GDPR. According to national

28001 – Madrid sedeagpd.gob.es 5/26 hereinafter, LPACAP), for the alleged violation of article 5.1.f) of the RGPD and article 32 of the RGPD, typified

publication to have been lawful due to the legitimate interest (per Article 6(1)(f) GDPR) it pursued. However, in June 2020 the claimant provided evidence to

83.5.b) of the RGPD. " FOURTH: THAT for the purposes provided for in art. 64.2 b) of Law 39/2015, of 1/10, of the Common Administrative Procedure of Public

Common Administrative Procedure of the Administrations Public (hereinafter, LPACAP) the director of the Council agreed to the accumulation and processing joint

OPENBANK, with in accordance with the provisions of articles 63 and 64 of the LPACAP, for the alleged infringement of Article 25 of the RGPD, typified in

grants each au- control authority and as established in articles 47, 48.1, 64.2 and 68.1 of the Law Organic 3/2018, of December 5, Protection of Personal

proceedings against the respondent, with in accordance with Articles 63 and 64 of Law 39/2015 of 1 October on the Common Administrative Procedure for Public

sedeagpd.gob.es 7/9 And later, in Annex f) it defines the concept of commercial communication of the Following way: "F) Commercial communication": any form

applicableindicated in article 64 of Law 39/2015, of October 1, on the ProcedureCommon Administrative of Public Administrations, which in its section f)establishes that

preparation of the record. That the analysis therefore focused on sections e) and f) of art. 6.1. 4. That it was not possible to determine precisely whether the

with Articles 63 and 64 of Law 39/2015 of 1 October on the Common Administrative Procedure of Public Administrations (‘the LPACAP’), for the alleged infringement

president nor C / Jorge Juan, 6 www.aepd.es 28001 - Madrid sedeagpd.gob.es Page 64 64/136 of the principal. Therefore, for the third party it is optional to ask

procedure for the exercise of rights. Secondly, you comment that article 64.5.f) authorizes you to issue a previous report. In this case, I regret to inform

absorption between CaixaBank Payments, E.F.C., E.P., S.A.U., the absorbed company, and CaixaBank Consumer Finance, E.F.C., S.A.U., absorbing company; both wholly

provisions of articles 63 and 64 of Law 39/2015, of October 1, on the Common Administrative Procedure of Public Administrations (LPACAP), for the following reasons:

Data andguarantee of digital rights and for the purposes provided in article 64.2, theDirector of the Spanish Agency for Data Protection agreed to admit theclaim

article 72.1.e) of the LOPDGDD. “ "For the purposes specified in the art. 64.2 b) of Law 39/2015, of 1/10, on Procedure Common Administrative Law of Public

with article 83.4 a) of the RGPD. " "For the purposes specified in the art. 64.2 b) of Law 39/2015, of 1/10, of the Administrative Procedure Common Administrative

Constitution (SSTC 11/1981, of April 8, F. 7; 196/1987, of December 11 [RTC 1987, 196], F. 6; and regarding art. 18, STC 110/1984, F. 5). Those limits or may be direct

accordance with the provisions of Article 56(2) in relation to Article 57(1)(f), both of Regulation (EU) 2016/679 of the European Parliament and of the Council

Procedure. C / Jorge Juan, 6 www.aepd.es 28001 - Madrid sedeagpd.gob.es Page 64 64/141 It should be noted that any sanctioning procedure and, where appropriate

and article 73.t) of the LOPDGDD” "For the purposes specified in the art. 64.2 b) of Law 39/2015, of 1/10, on Procedure Common Administrative Law of Public

supervisory authority of another Member State of the European Union, form article 64.3 of this organic law. " Although the specific date of the agreement to process

specified in the art. 64.2 b) of Law 39/2015, of 1/10, on Procedure Common Administrative System of Public Administrations (LPACAP, hereinafter), the sanction