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Fine imposed for unsecured website

Fine imposed for unsecured website

Fine imposed for unsecured website for registration of new orthodontic patients. 


Patient personal data was found to be at risk, including citizen service numbers, when an orthodontic practice allowed new patients to sign up via an unsecured website. According to this report, several fields of mandatory personal information were captured on an unsecured connection. This could have resulted in a data breach, which could have led to fraud, with several individuals affected, including minors. The Dutch DPA has imposed a fine of €12,000 on an orthopedic practitioner. 

Sensitive personal data was at risk of being accessed by unauthorized parties. 


An unsecured connection was used to capture mandatory personal information from new patients signing up for orthodontic services. 


The unsecured website being used to capture information from new patients included a form, requiring the input of personal data into mandatory fields. The required information included patients’ parents’ information, their general practitioner, insurance information as well as their dentist and citizen service number. This information was sent over an unencrypted connection, making it unsecured. Individuals submitting their personal information while signing up on the website of an orthodontic practitioner are trusting that their sensitive data will be protected. In addition, the majority of orthodontic patients are children and young adults, so this case involved the personal data of several children. Data protection laws have specific safeguards for the sensitive data of children, who are considered a particularly vulnerable group. 


Fine imposed for unsecured website after a complaint was lodged about a privacy violation. 


A complaint was lodged with the Dutch DPA regarding a privacy violation. Because the complaint was regarding poor security within the health sector, a sector with particularly strict privacy requirements, this complaint was taken very seriously by the DPA. Monique Verdier, the DPA’s deputy chair commented on the situation stating “When you register with an orthodontist, you entrust your personal data to them. This is data that the practice needs, but it is also of interest to criminals. Taking good care of your patients includes taking good care of their personal data. This applies to all care providers, not just large institutions.” It is a business’ responsibility to ensure that its website is GDPR compliant, and to secure customer data and websites, preventing possible data breaches, phishing, and other forms of malicious online activity. A fine of €12,000 was imposed on the orthodontic practitioner for this infraction. 


An objection to this fine was lodged, which the DPA declared unfounded. 

The fine imposed on the orthodontic practitioner is not final, and was challenged by the provider. While the fine may be revocable, the DPA has called the objection by the practitioner unfounded. An application for judicial review can be submitted to the district court to have the €12,000 fine revoked. If this is done, the final decision will rest in the hands of the district court. 


Does your company have all of the mandated safeguards in place to ensure compliance with the GDPR, Law Enforcement Directive and Data Protection Act 2018? Aphaia provides both GDPR and Data Protection Act 2018 consultancy services, including data protection impact assessments, and Data Protection Officer outsourcing. We can help your company get on track towards full compliance. Contact us today.

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