TL;DR for the DPO
Industry trackers (DLA Piper, Enforcement Tracker) put cumulative GDPR fines since 2018 above EUR 7.1 billion across 1,400+ decisions. Over 60% came after January 2023. Article 6 legal-basis violations alone account for about a third of actions.
Myth: 'fines only hit the giants'
False. A significant share of fines hit small organisations: local providers, agencies, small software houses. Absolute amounts are lower, but severity is proportional. SMEs are exactly the external DPO's typical client.
Key criterion: IMPLEMENTED controls
Fine-calculation guidelines reward demonstrable, active technical measures. Fragmented logs across disconnected systems are not audit-ready evidence.
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