3 February 2024

Adyen Collaborates with BILL to Enhance Financial Solutions for SMBs

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Adyen, a leading financial technology platform for businesses, has recently announced an exciting partnership with BILL, a prominent financial operations platform specializing in small and midsize businesses (SMBs). This collaboration aims to bring about significant advancements in financial solutions tailored for SMBs, marking a pivotal moment in the industry. The focus of this partnership is […]

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Mastering the Art of Traveling Sales: A Guide to Efficiency on the Road

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Traveling for sales may sound like an exciting adventure, but seasoned professionals know it’s far from a leisurely journey. The life of a traveling salesperson is filled with hectic schedules, constant movement, and the need to juggle multiple responsibilities on the go. However, with the right strategies in place, navigating the challenges of life on

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Supporting Grieving Colleagues: Navigating Loss with Empathy and Care

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In the realm of professional settings, where productivity and efficiency often take precedence, the delicate topic of grief can be daunting to address. The return of a colleague after experiencing the loss of a loved one brings about a myriad of emotions and challenges, prompting coworkers to navigate a fine line between offering meaningful support

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Post-Brexit: data protection
Card processor sends sensitive data to wrong address
24 August 2022

Worldline SA subsidiary Payone GmbH has been accused of breaching data protection rules after it sent sensitive employee payroll information to the wrong address by accident. The Worldline Group holdS a 60% stake in the Frankfurt based company who have a small UK market presence.

In June 2021, one of Payone GmbH’s ex UK employees (the data subject) received a “potential data breach notification” from the firm advising him that his salary, National Insurance data, nationality (Special Category Data) was amongst various bits of information sent to an incorrect home address.

This included personal information such as the former employees name, age and address.  It also included details such as the date of birth and the amount of annual work bonus he received in his bank account amongst other identifiable data.

Payone GmbH confirmed that this document was sent out in error following an employee making a mistake when re-entering data processed by their third-party payroll provider.  The error arose when the employee was fulfilling an Article 15 GDPR request. The error was spotted by the data subject when he noticed in an email version of the document that the postal address was incorrect. An attempt to notify Payone GmbH of the error went in vain as the document was already irretrievably despatched.

The data subject was alarmed with the incident which exposed him to the possibility of fraudulent activity, amidst reasonable fears his data could end up on the dark web and used by criminals.  Habitually resident in the UK he complained to the Information Commissioner’s Office (ICO) in June 2021. He similarly raised the concern in Germany via The Hessian Commissioner for Data Protection and Freedom of Information (HBDI).

The ICO reprimanded Payone GmbH for the error in their final decision letter.
Similarly, the HBDI cited a violation of Article 5(f) of the General Data Protection Regulation (GDPR) relating to integrity and confidentiality.

The ICO stated in their July 2021 findings that Payone GmbH, “should take steps to ensure that all personal data records are accurate and up to date. Holding inaccurate information, such as addresses, does increase the risk of personal data breaches and poses risks to the security of information”.

The HBDI confirmed in their October 2021 findings that Payone GmbH had taken remedial action. They concluded that a monetary fine would not be imposed on Payone GmbH as they had taken technical and organisational steps in response to the data breach. Data subjects could now request their data in an autonomous portal.

The GDPR, which came into effect in 2018, gave the Information Commissioner’s Office greater powers to tackle data breaches. The new ‘UK GDPR’ charts its own course after Brexit whilst seeking to maintain EU GDPR adequacy.  In extreme scenarios, organisations face penalties of up to £20m or 4 per cent of their global worldwide turnover, whichever is more.

In the years prior to GDPR, the ICO fines were capped at £500,000.

The data subject said: “I am just glad I spotted it; they were going to resend the document again to another wrong address. Prior to Brexit the process would have been commenced via the ICO who in turn would liaise with the HBDI on the data subjects’ behalf; but I found myself communicating with both authorities separately which was an additional step but in the end was surprisingly
effective. Unfortunately, Payone GmbH again sent my incorrect address to the
Workers Pension Trust in January 2022, and documents yet again went to the wrong address. In my opinion they have not learned from the first time and my complaint is sitting with the ICO yet again”.

The former employee is pursuing a remedy under Article 82 UK GDPR via
the Court’s of England & Wales.

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