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Global data risk
Fine reductions and reversals
In recent years there has been a trend towards fines being reduced or even reversed, either by the courts or the DPAs themselves.
In some cases, the courts have stepped in to reduce fines deemed unreasonably high, or because the DPA in question had misinterpreted or misapplied the law.
Where DPAs are concerned, there are a number of factors that contribute to fines being cut:
- Prompt notification and communication with the relevant authorities.
- Co-operation during the investigative process.
- The development of an action plan to show how the problem will be solved and/or a commitment to increasing the level of data protection.
- Voluntary payment (only Spain).
- External factors such as the financial impact of the COVID-19 crisis (eg the UK ICO cut Ticketmaster UK’s fine by £500,000).
- Reassessment of the underlying facts.
For further insights on how authorities set fines and how to respond to a regulatory investigation, please request a copy of our report Anatomy of a Data Breach: what really happens in a global cyber crisis?
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Giles Pratt Partner
Geoff Nicholas Partner
Rachael Annear Counsel
Rhodri Thomas Partner
Timothy Harkness Partner
Peter Jaffe Special Counsel
Norbert Nolte Partner
Dr. Christoph Werkmeister Partner
Richard Bird Partner