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Greece: HDPA fines Ministry of Rural Development and Food €25,000 for non-appointment of DPO and noncooperation with the Authority

On February 22, 2024, the Hellenic Data Protection Authority (HDPA) published its Decision No. 2/2024, as issued on January 29, 2024, in which it imposed a fine of €25,000 on the Ministry of Rural Development and Food (the Ministry) for violations of the General Data Protection Regulation (GDPR), following a questionnaire sent by the HDPA to selected public bodies.

Background to the HDPA's decision

In particular, the HDPA noted that the decision arose from the HDPA's participation in the European Data Protection Board's (EDPB) 2023 coordinated enforcement action on data protection officers (DPOs), where the HDPA sent a questionnaire on the definition and the position of DPOs to selected public bodies, including the Ministry. Subsequently, the Ministry did not respond to the questionnaire and further communications sent by the HDPA in a timely manner. Therefore, the HDPA sent a summons to the Ministry to discuss the case, in which case the Ministry sent a memorandum in response. Moreover, in the memorandum, the Ministry explained that from the period from August 4, 2022, to June 20, 2023, there was no DPO appointed as the tenure of the previous DPO had expired, and there was a lack of the necessary credit to renew the appointment.  

Findings of the HDPA

The HDPA found that the Municipality was in violation of Article 31 of the GDPR regarding the non-cooperation of the controller with the supervisory authority. Additionally, the HDPA found a violation of Article 37 of the GDPR regarding the non-designation of the DPO for the period from August 4, 2022, to June 20, 2023.


As a result, the HDPA fined the Ministry €25,000 for the aforementioned violations.

You can read the press release here and the decision here, both only available in Greek.