Home / People / Paulina Komorowska

Paulina Komorowska

Senior Associate

CMS Cameron McKenna Nabarro Olswang Pośniak i Bejm sp.k.
Warsaw Financial Centre
ul. Emilii Plater 53
00-113 Warsaw
Languages Polish, English, German

Paulina Komorowska is an advocate and a member of the CMS IP/TMT Group at CMS. She also has extensive experience in the field of competition and consumer protection law.

She has advised clients for more than 6 years primarily on the protection of personal data, e-commerce, consumer and competition law. Paulina supports clients from a variety of industries, including new technologies, online services and the pharmaceutical industry.

Paulina’s experience includes assistance in all aspects of personal data protection, including compliance audits, development of regulations, policies and instructions, compliance with the General Data Protection Regulation (GDPR), proceedings before the Polish data protection authority, preparation of agreements for entrusting data processing, data transfers, development of whistleblowing programmes and assistance in the scope of personal data protection in employee-employer relations. Paulina also advises on all aspects of conducting online activities and providing services by electronic means.

Paulina specialises in issues related to counteracting unfair competition, including unfair advertising, consumer protection, proceedings before the President of the Office of Competition and Consumer Protection, representation before administration bodies during inspections (dawn raids), as well as anticompetitive practices and abuse of dominant position.

She provides trainings for clients and participates in scientific and industry conferences. She has authored several publications, and is a co-author of one of the leading commentaries on the Competition and Consumer Protection Act. She is a doctoral student at the Institute of Legal Studies at the Polish Academy of Sciences.

more less

Relevant experience

  • Auditing compliance with personal data protection law of companies from a group operating in the hotel industry
  • Conducting a compliance audit related to personal data processing by an online social platform operator
  • Advice on the development of internet platform regulations for compliance with the GDPR, consumer law and the Act on providing services by electronic means
  • Representing a client from the sports industry during a dawn raid by the Polish competition and consumer protection authority
  • Advice on the development of rules of conduct in the case of an unannounced inspection (dawn raid) by the Polish competition and consumer protection authority for entities operating in the insurance industry, the household appliances industry and other industries
  • Conducting workshops on the implementation of the General Data Protection Regulation (GDPR) at a leading postal operator
  • Advising on the appointment of a personal data controller in a company from the pharmaceutical sector
  • Conducting a legal compliance audit of personal data flows outside the EEA between companies in a group from the pharmaceutical sector
  • Acting before the Polish competition and consumer protection authority in proceedings against an entity from the dietary supplements industry with regard to unfair advertising
  • Advice on the development of a whistleblowing programme in a company operating in the energy industry
  • Advice to a marketing industry entity on the admissibility of transferring data to a non-EEA country
  • Advice to a pharmaceutical sector company on the compliance of a franchise agreement with the personal data protection law and competition law
  • Advice on the development of a compliance policy in companies from a group operating in the energy sector 
more less


  • Ph. D. candidate at the Polish Academy of Sciences
  • 2011 – Master of Law, Jagiellonian University, Warsaw
  • 2010 / 2011 – Erasmus scholarship, K.U. Leuven, Leuven
more less
15 November 2017
CMS con­tin­ues to in­vest in its in­tel­lec­tu­al prop­erty...


Show only
22 August 2019
The Auto­mot­ive In­dustry Re­port 2019/20
05 Nov 19
Whis­tleblow­ing Dir­ect­ive ad­op­ted by the EU Coun­cil
On 7 Oc­to­ber 2019, the EU Coun­cil ap­proved the word­ing of the "Dir­ect­ive of the European Par­lia­ment and of the Coun­cil on the pro­tec­tion of per­sons who re­port breaches of Uni­on law", also known as the...
07 Oct 19
High fine im­posed by the Pol­ish Data Pro­tec­tion Au­thor­ity for an in­fringe­ment...
Re­cently, the Pol­ish Data Pro­tec­tion Au­thor­ity (UODO) im­posed a fine of EUR 660,000 (PLN 2,830,410) on Mo­rele.net Sp. z o.o., a com­pany op­er­at­ing in the e-com­merce sec­tor. This is the third fine im­posed...
19 Jul 19
Po­land: New list of op­er­a­tions that re­quire a data pro­tec­tion im­pact...
Re­cently, UODO – the Pol­ish data pro­tec­tion au­thor­ity – an­nounced a mod­i­fied list of the types of per­son­al data pro­cessing op­er­a­tions that re­quire a data pro­tec­tion im­pact as­sess­ment (List)*. What...
01 Apr 19
First fine for GDPR in­fringe­ment in Po­land
The Pol­ish data pro­tec­tion au­thor­ity – UODO – has im­posed a fine of al­most PLN 1 mil­lion (equi­val­ent to EUR 220,000) on a con­trol­ler for fail­ing to ful­fil the in­form­a­tion ob­lig­a­tion un­der Art­icle...