Sun, Sep
66 New Articles

GDPR Fine of 1,1 Million Euro Imposed on Volkswagen

GDPR Fine of 1,1 Million Euro Imposed on Volkswagen

  • Smaller Small Medium Big Bigger
  • Default Helvetica Segoe Georgia Times

In a decision published on 26 July 2022, Austrian data protection authority established that Volkswagen was in violation of Articles 13, 28, 35 and 30 of the GDPR.

The problem was initially discovered by the Austrian police when Volkswagen’s test car was stopped for a traffic control. The police noticed unusual extension on the vehicle, which turned out to be cameras that recorded traffic around the vehicle in order to test and train the driving assistance system for avoiding traffic accidents.

However, there was no sign on the vehicle, so other drivers were not informed that their personal data were being processed, who was processing the data, for what purpose and how long the data would be stored.

More violations were found in the lack of a data protection impact assessment (DPIA) and data processing agreement with the service provider that carried out the test drives.

Lastly, in the register of processing activities, there was no description of technical and organizational security measures which have to be implemented pursuant to Article 32 of the GDPR.

Besides these low-severity violations, no issues were identified with regard to collection and further processing of personal data. In line with Article 83 of the GDPR, when determining the amount of the fine, the supervising authority also considered the meaningful purpose of recording (increasing road safety), and the fact that Volkswagen cooperated during the proceeding and immediately remedied the defects.

By Marta Jelakovic, Senior Associate, Ostermann & Partners

Ostermann & Partners at a Glance

Ostermann & Partners is a full-service Croatian corporate law firm advising local and international companies, financial and governmental institutions.

For more than a decade, we have been providing comprehensive legal services and transactional advice to our clients in the following areas: Banking & Finance, Capital Markets, Corporate, Commercial and M&A, Employment, Energy, Project Finance, Real Estate and Restructuring & Insolvency. Furthermore, we have developed a particular expertise in representing clients in all types of disputes (litigation and arbitration) where our in-depth and thorough approach has been particularly recognised by both peers and clients.


We are recognised for the clarity, promptness, and straightforwardness of our advice.

Our team is made out of energetic, solution-oriented, business savvy experts who always focus on client’s business goals. Professional excellence and profound commitment to our clients are our core values.

Our approach is based on critical analysis and legal research of local, European and international legal practice.

We place strong emphasis on developing a comprehensive understanding of our clients’ businesses. Our lawyers respond timely and effectively by giving you advice instead of just options. We look at the big picture and the fine details.


Ostermann & Partners has been recognised internationally by some of the leading independent quality researchers such as Legal 500, Chambers and Partners, and IFLR 1000 for excellence, while our lawyers have been recognised as market leaders.

Firm's website.