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Isle of Man: Commissioner imposes £3,250 fine on Cosmetic Medical Limited for non-compliance with orders
The Information Commissioner issued, on 11 December 2020, a penalty notice to Cosmetic Medical Limited ('CML') in which it imposed a fine of £3,250 under Articles 12, 15, and 31 of the Data Protection (Application of GDPR) Order 2018 ('the Applied GDPR'). In particular, the Commissioner outlined that it had received a complaint from a data subject regarding CML's compliance with their request to exercise the right of access to personal data. Furthermore, the Commissioner recalled that the data subject, as CML's suggestion, submitted a subject access request to CML, to which CML failed to comply under the requirements of Articles 12 and 15 of the Applied GDPR. Nevertheless, the Commissioner noted that the penalty does not relate to non-compliance with the request, but to CML's engagement with the Commissioner during investigations. More specifically, CML failed to respond to the Commissioner's request for information in the prescribed time period and accordingly provided information that did not relate to CML's compliance with the subject access request. In terms of aggravating factors, the Commissioner found that it is the first penalty imposed on CML.
You can read the penalty notice here.
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