Monthly Archive: September 2015

German DPA Imposes Significant Fine for Commissioned Data Processing Without a Proper

By: Dr. Thomas Jansen and Mari Martin On August 20, 2015, the Bavarian Data Protection Authority (DPA) issued a press release stating that it had imposed a significant fine on an organization that engaged in commissioned data processing without first concluding a proper data processing agreement. Background Pursuant to section 11 of the German Federal …

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