10 Biggest CCO/DPO-related Fines

Here are some of the biggest CCO/DPO-related fines over the years, primarily stemming from violations of data privacy regulations such as the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). These fines underscore the legal accountability that Chief Compliance Officers (CCOs) and Data Protection Officers (DPOs) face in managing compliance with evolving privacy laws.

https://www.compliancehub.wiki/cco-and-dpo-legal-case-and-corporate-fines

Violation: Amazon was fined a record-breaking €746 million by Luxembourg’s National Commission for Data Protection (CNPD) for non-compliance with GDPR, particularly regarding how it processes personal data for targeted advertising.
Key Issue: The CNPD ruled that Amazon’s data processing practices were not sufficiently transparent or lawful under GDPR, particularly in terms of how it collected and used customer data for advertising purposes.
Impact: This remains the largest GDPR fine to date and serves as a critical reminder of the need for comprehensive transparency and legal justification when processing personal data. Amazon’s CCO and DPO were tasked with responding to this fine and ensuring future compliance.

Violation: Meta (Facebook) was fined €405 million by the Irish Data Protection Commission (DPC) for mishandling children’s data on Instagram.
Key Issue: The fine was levied due to the improper handling of children’s personal data, particularly in the context of their use of Instagram. Instagram allowed the public display of email addresses and phone numbers of minors using business accounts, in violation of GDPR’s provisions on child data protection.
Impact: This fine underscored the importance of protecting minors’ data and transparency in data processing practices. Meta’s DPO played a critical role in addressing these issues and ensuring compliance moving forward.

Violation: In another blow to Meta, the Irish DPC fined the company €265 million in late 2022 for a data breach that exposed personal information of more than 500 million Facebook users.
Key Issue: The breach was traced back to 2018 and involved scraping user data from publicly available Facebook profiles. This violation was seen as a failure to implement adequate security measures to protect personal data, as required by GDPR.
Impact: Meta’s CCO and DPO faced scrutiny for their failure to adequately secure user data, prompting internal reviews and efforts to strengthen their compliance and data security practices.

Violation: In 2019, the French Data Protection Authority (CNIL) fined Google €50 million for failing to comply with GDPR’s transparency and consent requirements, particularly regarding how it personalized ads.
Key Issue: CNIL found that Google had failed to provide users with sufficient transparency about how their data was being used and processed, particularly regarding personalized advertising. Furthermore, the process for obtaining user consent was not considered valid under GDPR’s stringent requirements.
Impact: Google’s CCO and DPO were responsible for addressing the transparency and consent processes after the fine. The case set an important precedent for how companies must clearly communicate data processing activities and obtain valid user consent under GDPR.

Violation: The German Data Protection Authority fined H&M €35.3 million for illegally monitoring employee behavior, collecting and storing personal data without proper consent or justification.
Key Issue: H&M was found to have maintained excessive records about employees’ private lives, including personal issues and health data, which were used in employment decisions. This violation of GDPR’s principles around data minimization and employee privacy led to one of the largest GDPR fines involving workplace data.
Impact: The fine highlighted the role of CCOs and DPOs in ensuring that companies respect the privacy of not just customers but also employees. The case reinforced the need for robust internal policies to prevent illegal monitoring and collection of sensitive personal data.

Violation: British Airways was fined £20 million (reduced from £183 million due to COVID-19 financial impacts) by the UK Information Commissioner’s Office (ICO) following a massive data breach in 2018.
Key Issue: Hackers exploited vulnerabilities in British Airways’ website to steal personal and payment data of approximately 400,000 customers. The ICO found that British Airways had failed to implement adequate security measures to protect customer data.
Impact: This was one of the largest GDPR fines in the UK and emphasized the importance of strong cybersecurity practices for compliance with data protection laws. British Airways’ CCO and DPO were critical in responding to the fine and implementing improved security protocols.

Violation: Marriott International was fined £18.4 million by the ICO in 2020 following a data breach that affected approximately 339 million guest records, including sensitive personal information such as passport numbers and credit card details.
Key Issue: The breach, which occurred in Starwood’s guest reservation database and went undetected for four years, was deemed a failure by Marriott to secure personal data. The ICO also criticized Marriott for failing to conduct proper due diligence during its acquisition of Starwood, which had been compromised before the merger.
Impact: This case underscored the importance of CCOs and DPOs in mergers and acquisitions, highlighting the need for due diligence on data protection and cybersecurity risks when acquiring new businesses.

Violation: In 2022, France’s CNIL fined Clearview AI €20 million for unlawfully collecting biometric data (facial images) without obtaining the proper consent from individuals. The company scraped billions of images from social media platforms and other websites to build a facial recognition database.
Key Issue: GDPR mandates explicit consent for processing biometric data, which Clearview AI failed to obtain. The company’s DPO faced criticism for not ensuring compliance with GDPR’s strict provisions on biometric data processing.
Impact: This fine sent a strong message regarding the lawful collection and processing of biometric data under GDPR. Clearview AI was ordered to delete all data collected from European citizens, further underscoring the role of DPOs in managing sensitive data.

9. Equifax – $700 Million Settlement for Data Breach (2019)

Violation: Although not strictly under GDPR, Equifax agreed to a $700 million settlement with the U.S. Federal Trade Commission (FTC), Consumer Financial Protection Bureau (CFPB), and U.S. states following a massive 2017 data breach that affected 147 million consumers.
Key Issue: The breach exposed sensitive personal information, including Social Security numbers, birth dates, and addresses. Equifax was found to have failed in its duty to implement adequate security measures and notify consumers in a timely manner.
Impact: Equifax’s CCO and data security leadership faced intense scrutiny for the company’s failure to protect consumer data. The breach, and the subsequent fine, reinforced the need for robust compliance programs and data security measures across industries.

10. Uber – $148 Million Settlement for Data Breach Cover-Up (2018)

Violation: Uber was fined $148 million in 2018 after it was revealed that the company had paid hackers to cover up a 2016 data breach that exposed personal information of 57 million drivers and passengers.
Key Issue: Instead of notifying authorities and users of the breach, Uber paid the hackers to delete the data and remain silent, concealing the breach from the public for over a year. This was a clear violation of breach notification laws in the U.S. and EU.
Impact: Uber’s CCO and legal team faced scrutiny over their decision to cover up the breach, and the case set a precedent for how breach notifications must be handled transparently. The fine highlighted the legal and ethical responsibilities of CCOs in managing data breaches.

Analyzing Two Pivotal CISO Cases: USA v. Sullivan and SEC v. SolarWinds

Key Takeaways for CCOs and DPOs

Transparency and Consent: Many of the largest fines, such as those against Google, Meta, and Clearview AI, have revolved around transparency issues and the proper collection of user consent. Ensuring that companies provide clear information about data usage and obtain valid consent is critical under GDPR and CCPA.
Cybersecurity and Data Breaches: Fines against companies like British Airways, Marriott, and Equifax illustrate the importance of strong cybersecurity measures. CCOs and DPOs must ensure that personal data is secured with appropriate technical and organizational measures.
Employee Data Protection: The fine against H&M highlights that GDPR protections extend to employee data. CCOs and DPOs must ensure compliance not just with customer data, but also in how employee data is collected, stored, and used.
Accountability for Vendors and Mergers: Both Marriott and Ticketmaster faced fines due to third-party vulnerabilities. CCOs and DPOs must ensure that vendor relationships are managed carefully and that due diligence is performed during acquisitions to assess data protection risks.

https://www.securitycareers.help/9-notable-ciso-legal-cases

These fines demonstrate the increasingly significant role of CCOs and DPOs in safeguarding personal data, ensuring regulatory compliance, and mitigating the financial and reputational risks associated with privacy violations.