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Methodology & Contacts

The small print for the ET Report reads as as follows:

  • The ET Report is based on the fines included in the Enforcement Tracker. The Enforcement Tracker only contains publicly available fines. As we are aware that DPA policies in relation to the publication of fines vary between DPA/jurisdictions, we know that the content of the Enforcement Tracker and, hence, the basis for the ET Report, is necessarily incomplete. However, this approach is the only available option so far, and we will continue to work on this basis.
  • The Enforcement Tracker and this ET Report consider fines from all EU Member States as well as from the UK.
  • This third edition of the ET Report covers all fines from 2018 to the editorial deadline of 1 March 2022. As at the editorial deadline of 1 March 2022, the Enforcement Tracker covered some 1,088 fines.
  • The aim of this Enforcement Tracker Report is to categorise and analyse the identified fines. However, some DPAs have levied fines against unknown controllers, fines of an unknown amount or in unknown sectors. Such fines have not been included in the ET Report. This anonymity of some fines also explains the discrepancy between the overall number/amount of fines included in the Enforcement Tracker (1,088 as of 1 March 2022) and those we have included in this Enforcement Tracker Report (1,031 as of 1 March 2022).
  • Each fine is assigned to only one sector (business sector or “Employment”) depending on the main focus of the data processing. For fines that could be allocated to several sectors, we have taken a focal point approach and placed more specific sectors (e.g. Employment – which only contains fines related to employee data protection) ahead of more general sectors (e.g. Industry & Commerce).
  • All fines in the Enforcement Tracker are assigned a unique and permanent “ETid”. These ETids are also used by the ET Report when referring to specific fines – the details of a case are just a click away.

No risks and side effects have been brought to our attention so far. If you detect something odd, suspicious or otherwise worth reporting while reading the ET Report or using the Enforcement Tracker, please feel free to reach out to us.

Key contacts

Christian Runte
Partner
Rechtsanwalt
Munich
T +49 89 23807 163
Michael Kamps
Partner
Rechtsanwalt
Cologne
T +49 221 7716 372
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