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Worker’s Resilience Leads to Victory in UK, TUPE Employment Case

Leave a Comment / Employment, Wellbeing /

What is a TUPE? In the Employment Appeal Tribunal (EAT), employee Gary Lewis (GL) won his second appeal against his former employer, Dow Silicones UK Limited. The case focussed on the protections afforded to employees under the Transfer of Undertakings (Protection of Employment) Regulations 2006 (TUPE). This case centered on whether the changes to Lewis’s […]

Worker’s Resilience Leads to Victory in UK, TUPE Employment Case Read More »

Spotlight on Nets: Pioneering Payment Solutions in Europe

Leave a Comment / AML Compliance, Payments, Retail /

The Nets story Nets, the result of a strategic merger between Denmark’s PBS and Norway’s BBS in 2009, has grown to become a significant force in the European payments industry. With the acquisition of Finland’s Luottokunta in 2012, the company catapulted into the top league of European payment processors. Nets has demonstrated a remarkable ability

Spotlight on Nets: Pioneering Payment Solutions in Europe Read More »

Crédit Agricole and Worldline Unveil CAWL In Crowded French Fintech Market

Leave a Comment / Payments, Retail /

In a bold move within the realm of payment services, global paytech giant Worldline and leading French banking institution Crédit Agricole have joined forces to introduce CAWL, a new joint venture aimed at revolutionising merchant payment solutions in France. The unveiling of CAWL marks a significant milestone in the ever-evolving landscape of financial technology, promising

Crédit Agricole and Worldline Unveil CAWL In Crowded French Fintech Market Read More »

N26 Launches Stock and ETF Trading in Germany

Leave a Comment / Payments /

N26, a challenger bank and a prominent European digital banking institution, has recently introduced a new feature to its suite of financial products in Germany. This addition allows customers to trade stocks and exchange-traded funds (ETFs) directly through the N26 mobile application. What is a challenger bank? Challenger banks, also known as neobanks, represent a

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A Closer Look at Recent Employment Appeal Tribunal Ruling on Reasonable Adjustments for Employees with Disabilities

Leave a Comment / Employment, Wellbeing /

In a recent tribunal ruling (Rentokil Initial UK Ltd v Mr M Miller: [2024] EAT 37) that dismissed Rentokil’s appeal, significant insights were gleaned regarding the rights of employees with disabilities. The case, which centered on the dismissal of an employee with a disability, provided an examination of the duty of employers to make reasonable

A Closer Look at Recent Employment Appeal Tribunal Ruling on Reasonable Adjustments for Employees with Disabilities Read More »

The Imperative of Organizational Health

Leave a Comment / Employment /

What is organizational health? A closer look Imagine your company as a human body. Just like our bodies need a strong immune system and clear goals (staying healthy, fighting off illness) to function at their best, organizations need a robust “organizational health” to achieve consistent success. This translates to three key pillars: a shared vision

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Klarna’s Wikipink: A Paradigm Shift in Credit Transparency?

Leave a Comment / Payments, Retail /

The credit landscape just witnessed a seismic shift. Klarna, the reigning champion of Buy Now, Pay Later (BNPL), has launched a bold initiative called Wikipink, wielding data as a weapon to dismantle the industry’s traditional opaqueness. This move has sent shockwaves through the financial world, sparking a flurry of questions about Klarna’s true intentions. Is

Klarna’s Wikipink: A Paradigm Shift in Credit Transparency? Read More »

Florian Risch, The Employee Who Thought It Was Okay To Laugh And Tell Anecdote About “Black Man Having Sexual Intercourse With An Animal” During Workplace Dinner.

Core values /

When asked what the laughter was all about during a work dinner, the Payone GmbH employee Florian Risch told the only black employee attending the dinner that he was making reference to a “black man having sexual intercourse with an animal”. 

Florian Risch, The Employee Who Thought It Was Okay To Laugh And Tell Anecdote About “Black Man Having Sexual Intercourse With An Animal” During Workplace Dinner. Read More »

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Strategic Considerations for Retail Finance Directors

Leave a Comment / AML Compliance, Payments, Retail /

In the ever-evolving landscape of retail finance, Finance Directors play a pivotal role in steering their organizations through regulatory frameworks that impact their bottom line. One such regulation with far-reaching implications is the EU Interchange Fee Regulation (EU IFR). Enacted to address concerns of anti-competitive behavior in card-based payment transactions, the EU IFR imposes caps

Strategic Considerations for Retail Finance Directors Read More »

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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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