The Advocate General’s Opinion emphasizes that supervisory authorities must consider the total annual turnover of an entire corporate group when imposing GDPR fines.
To assess if a group of companies forms an 'undertaking', SAs need to evaluate the extent of the parent company’s control over its subsidiaries.
The Opinion outlines a two-step process for determining fines, starting with assessing the maximum fine and then considering the specific context of the individual case.
It is crucial for SAs to ensure that the fines imposed under the GDPR are effective, proportionate, and dissuasive, aligned with the regulatory intentions.
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