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In a recent judgment of April 26, 2021, the Belgian Data Protection Authority (“DPA”) fined a financial institution (the “Company”) €100,000 for – amongst other things – failure to provide an adequate level of cybersecurity. This is the second highest fine to date and should serve as a huge warning for all companies: The return on investment in cybersecurity is worth your while!
Additionally, the DPA adopted a more functional approach on combining the role of data protection officer (“DPO”) with other leading functions within a company. A lot to cover!
1. Facts
The case started with a complaint from a former spouse (“Complainant”) against the Company, as employer of her ex-husband. During the process of liquidating their joint estate, the ex-husband had used his access to the Central Individual Credit Register (“CICR”) of the National Bank of Belgium to research the personal/financial data of h