Setúbal City Council may be punished with a maximum fine of €10 million, if it is confirmed that there is no specific contract for the allocation of a municipal computer to Igor Khashin or to the Edintsvo Association, to provide care and data collection services to Ukrainian refugees. Speaking to Expresso, Martim Bouza Serrano, Partner and Managing Associate of CCA's TMT Area, explains why this situation may trigger a sanction from the National Commission for Data Protection (CNPD).
"It is not enough for there to be a protocol, the law requires that a personal data processing agreement be signed between the two entities in question, with specific clauses and obligations that regulate how the data processing should be processed," explains the partner.