UODO

Map of Warsaw, PolandThe reorganization of the Personal Data Protection Office (UODO), which took place in December 2019, warrants an assumption that 2020 will see increased activity from the supervisory authority. The UODO’s creation of three new departments indicates that the officers intend to specialize further to boost the efficiency of personal data protection inspections, in particular data breaches. Therefore, it is worth analyzing the definition of a breach, based on the decisions issued by the President of UODO in 2019.
Continue Reading Poland: Expected Enforcement Actions in 2020 and Beyond. Who Should Beware?

Map of Warsaw, Poland

On September 9, the Polish Data Protection Supervisory Authority (UODO) issued its response to the letter of the President of the Polish Bank Association, wherein it clearly stated that the provision of the banking law (i.e. article 112b of the act) does not entitle banks to make copies of personal ID cards of their clients at all times (e.g. for the purpose of setting up a bank account or checking the client’s credibility). In the regulator’s opinion, making copies is permitted only when the law explicitly authorizes one to do so.
Continue Reading Polish Data Protection Authority’s Position on Making Copies of Identity Documents by Banks