After a month of rumors, uncertainty, and German data protection
authorities being nontransparent, the German conference of data
protection authorities (Datenschutzkonferenz,
DSK) published the concept for
calculating administrative fines for data protection violations
(Concept, available here) on October 16, 2019.
The Concept sets out a standardized approach regarding the
calculation of administrative fines in accordance with article
83(4) and (5) of the General Data Protection Regulation (GDPR) and
also takes into account the circumstances of the individual case as
described in article 83(2) GDPR. The Concept provides a uniform
determination of administrative fines under GDPR without losing the
flexibility to consider the individual case and situation of the
violating person or organization (Violating
Entity).
