The group appointed a DPO as a part of its data protection office located at its headquarters, while its Luxembourg subsidiary only had a data protection lawyer that acted as a point of contact for the DPO; this structure precluded the DPO from being informed and consulted from the earliest stages of all data protection matters in Luxembourg, as the lawyer only communicated with the DPO when they deemed it necessary.
Luxembourg CNPD Fines Group of Companies €18,000 for Lack of DPO Involvement
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