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The Danish Data Protection Agency has published new rulings regarding email encryption within the security of processing area


Article 32 of the GDPR on the security of processing has been one of the main focus areas of the Danish Data Protection Agency (the DDPA) in 2019.

The DDPA has issued several guidelines on the security of processing, including a guideline on email encryption and chose to complete several inspections in the private sector during 2019. The DDPA thus visited two law firms, one auditor firm and one labour union.


The result of the focus area and the controlling measures has been four rulings which now contribute to the understanding of the Danish regulations on the security of processing, including email encryption. Mainly the new practice specify when email encryption should be used, but it also states surrounding circumstances, e.g. that companies should prepare specific email risk assessments when handling confidential and sensitive data and that procedures to control domains and email addresses must be in place.

In the specific rulings the DDPA concluded that two of the four inspected companies followed article 32 of the GDPR and used the correct type of email encryption. The Authority also had reason to criticize the two other inspected companies, the labor union and one of the law firms, since they were not in compliance with article 32 of the GDPR. The Authority noted that the law firm did not have the correct procedures to handle confidential and sensitive data and had not prepared sufficient risk assessment. The trade union had sent emails without email encryption on areas where email encryption was necessary, and used personal identification numbers as passwords to read specific emails on a webserver. As a result of this, the DDPA ordered the trade union to cease the use of personal identification numbers as passwords. No fines were given to any of the four companies, but an injuction was addressed to the union and the lack of future compliance will result in a fine for the union.


The inspections are the overall result of the DDPA’s more enforcement related focus during 2019 and is expected to increase in 2020.


Article provided by: Dr. Claas Thöle


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