The French CNIL imposed a €400,000 fine on a company specialized in real estate development, purchase, sale, rental and property management, for failing to adequately protect the data of users of its website and for implementing inappropriate procedures for storing data.
The company operates a website on which users can create a file to apply for a rental and upload supporting documents. In August 2018, the CNIL received a complaint from a user who had been able to access, from his personal space on the website, documents registered by other users by slightly modifying the URL displayed in the browser. An online check was carried out in September 2018 by the CNIL and revealed that documents sent by applicants for rentals were freely accessible, without prior authentication. These documents included copies of ID, social security cards, tax returns, certificates issued by the family allowance fund, divorce judgments, account statements and bank account details.
The CNIL alerted the company of the existence of this security breach and subsequent violation of personal data. A few days later, the CNIL carried out an inspection at the company premises and discovered that the company had been aware of the issue since March 2018 but that, although it had initiated IT correction measures, it was not until 17 September 2018 that the issue was resolved.
The CNIL identified two violations of the GDPR:
Taking into account, on the one hand, the seriousness of the breach, the lack of diligence by the company in addressing the breach and the fact that the accessible documents revealed very private aspects of people’s lives, and on the other hand, the size of the company and its financial strength, the CNIL decided to impose a €400,000 fine on the company ( https://www.legifrance.gouv.fr/affichCnil.do?oldAction=rechExpCnil&id=CNILTEXT000038552658&fastReqId=119744754&fastPos=1).
Although the CNIL has seemed rather lenient up until now with regard to GDPR compliance, giving only formal notices to comply with the legislation, this first significant fine should be considered as a warning for companies.