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Polish DPA imposes a fine on Warsaw University of Technology

Polish DPA imposed a fine on Warsaw University of Technology for not complying with it’s obligations on the 9th of Dec 2021.

Background information

Date of final decision: 9 December 2021
National case
Controller: Warsaw University of Technology
Legal Reference: Principles (Art. 5(1)(f), Art. 5(2)), Data protection by design and by default (Art. 25(1)), Security of processing (Art. 32(1), Art. 32(2))
Decision: infringement of GDPR, fine issued
Key words: principles, processing, security, data protection

Summary of the Decision

Origin of the case

The proceedings against the Warsaw University of Technology was initiated after the Polish Data Protection Authority received a data breach notification. As it was indicated, an unauthorized person downloaded from the controller’s IT network resources a database containing personal data of students and lecturers (over 5 thousand people).

Key Finding

As it was established during the administrative proceedings, the establishment of the Warsaw University of Technology used an application created by the University’s employees to enrol for courses and allowed the user to have insight into the history of teaching, grades and calculations of fees. This application was modified depending on the controller’s needs. At the beginning of January 2020, an unauthorized person having credentials used the functionality of uploading files to the application. In turn, at the beginning of May 2020, an unauthorized download of personal data was made.

Warsaw University of Technology did not implement the appropriate technical and organizational measures to ensure the security of the personal data processed.

Moreover, the University failed to regularly test, assess and evaluate the effectiveness of measures and did not take into consideration the risk related to the processing of data within the application.

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Taking into account the controller’s failure to comply with its obligations and the high risk of adverse effects in the future for persons affected by the incident, the Polish Data Protection Authority found it reasonable and necessary to impose an administrative fine of PLN 45,000 (approximately EUR 9,900).

For further information (decision in the national language):

The news published here does not constitute official EDPB communication, nor an EDPB endorsement. This news item was originally published by the national supervisory authority and was published here at the request of the SA for information purposes. Any questions regarding this news item should be directed to the supervisory authority concerned.

Source: EDPB

What is the Polish DPA?

Polish DPA: The first fine for non-compliance with an administrative decision order. The new PDPA establishes a new supervisory body – the President of the Office for Personal Data Protection (hereinafter referred to as the “Polish DPA”), which has a much wider range of powers than the previous DPA (Inspector General for the Protection of Personal Data – hereinafter referred to as the Inspector General …

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Steven Black (n0tst3)
Hello! I'm Steve, an independent security researcher, and analyst from Scotland, UK. I've had an avid interest in Computers, Technology and Security since my early teens. 20 years on, and, it's a whole lot more complicated... I've assisted Governments, Individuals and Organizations throughout the world. Including; US DOJ, NHS UK, GOV UK. I'll often reblog infosec-related articles that I find interesting. On the RiSec website, You'll also find a variety of write-ups, tutorials and much more!

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