Date of final decision: 9 December 2021
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).
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.
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 national language):
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