POLISH DPA IMPOSES A PENALTY OF A REPRIMAND FOR THE PROCESSING OF STUDENTS’ PERSONAL DATA

10.09.2020

The President of the Personal Data Protection Board (“UODO”) has imposed penalty of a reprimand on a school for processing students’ personal data without a legal basis in connection with a school survey conducted in the 2019/2020 academic year.

The personal information shared with the school are family status (single parent, full family), information about death of a legal guardian (parent), separation of legal guardians (parents), their education and professional situation, the number of people in the household, financial situation, health condition etc.

According to the inspections findings, the personal data included in surveys were not recorded and processed in electronic and telecommunication systems. All copies returned by teachers were destroyed by an official commission.

The school may process personal data within the scope of the duties assigned by the law. However, according to the Education Law, schools process personal data to extent necessary for implement of duties and obligations arising from these regulations.

In the established circumstances of the case, the UODO President considered the reprimand to be sufficient and the unintentional nature of the violation was considered as mitigating circumstance.

You can read the full text of the decision here.

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Kind regards,

Zumbul Attorneys-at-Law

info@zumbul.av.tr