Expected increase in fines due to new fine model of the
supervisory authorities.
Largely unnoticed by the public, the "Conference of the
Independent Data Protection Supervisory Authorities of the
Federation and the Countries" (DSK) discussed a new
calculation model for fines already in June 2019. Similar to
antitrust law, this model is intended to facilitate a
comprehensible practice in the calculation of fines.
Despite explicit requests, the model itself is currently not to
be published. However, the model has already been used in practice
(only for test purposes, as the DSK stresses). According to initial
reports, the fine model will very probably lead to a significant
increase in fines. This should not come as a surprise in view of
the sharp increase in the legal threat of a fine of up to 4% of the
previous year's worldwide turnover or € 20 million. A
closer look at the available information, however, suggests that
fines such as the € 110 million already imposed
