Home / GDPR Enforcement Tracker Report / Methodology and contacts

Methodology and contacts

GDPR Enforcement Tracker Report - Methodology and Contacts

Every prescription drug comes with a package leaflet containing scary warnings about risks and side effects (Beipackzettel in German). We regret that there is also some small print for the Enforcement Tracker Report; our online-only package leaflet reads as follows:

  • The Enforcement Tracker 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/member states, we know that the content of the Enforcement Tracker and, hence, the basis for the Enforcement Tracker 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 Enforcement Tracker Report consider fines from all EU Member States as well as from the UK.
     
  • This second edition of the Enforcement Tracker Report covers all fines from 2018 to the editorial deadline of 1 March 2021. As at the editorial deadline of 1 March 2021, the Enforcement Tracker comprised some 570 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 Enforcement Tracker Report. This anonymity of some fines also explains the discrepancy between the overall number/amount of fines included in the Enforcement Tracker (570 as of 1 March 2021) and those we have included in this Enforcement Tracker Report (526 as of 1 March 2021).
     
  • Each fine is assigned to only one sector (industry 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).
     
  • Compared to the Enforcement Tracker Report 2020, we have included "Real Estate" as a new sector. In addition, we have also added "Education" to the "Public Sector" to cover public as well as private educational institutions.
     
  • All fines in the Enforcement Tracker are assigned a unique and permanent "ETid". These ETids are also used by the Enforcement Tracker Report when referring to specific fines. We have also included links to the Enforcement Tracker in the Enforcement Tracker Report, so that details on specific fines are just a click away.

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

Key contacts

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