GDPR / ANSPDCP fines: appeal support + remediation (compliance) plan

This service is for companies and organisations that received an ANSPDCP (Romanian data protection authority) sanction or investigation findings under GDPR. It focuses on two tracks: (1) contesting a fine or measures where the law provides a remedy, and (2) building a practical remediation plan to address findings and reduce repeat exposure, especially where processing involves multiple teams, vendors or joint responsibilities.

The information is general and does not replace legal advice. Facts, documents and timeline matter.

When you typically need this

  • You received an ANSPDCP decision/minute with a GDPR fine and need to assess challenge options and deadlines.
  • The authority imposed corrective measures (technical/organisational measures, policy changes, notices) and you need a workable plan.
  • You need to clarify controller/processor roles and responsibilities across vendors, group entities or departments.
  • The findings involve data subject rights requests (access, deletion, objection) and response handling.
  • The case involves security incidents, access control, logs, or data breaches and you need evidence and timeline clarity.
  • You want to reduce future exposure through documented compliance routines (records, DPIA, vendor contracts, training).
  • You have cross-border aspects and need alignment with EU guidance and Romanian practice.
  • You need to prepare for internal/external communication while keeping the legal file coherent.

What we do, step by step

  1. Fast framing: what decision/minute you received, what was found, what is sanctioned, and what deadlines apply (including service proof).
  2. Facts & timeline: what processing happened, by whom, on what systems, when, and what evidence exists.
  3. Document review: privacy notices, legal bases, contracts, technical/security controls, logs, and internal procedures.
  4. Legal assessment: GDPR obligations implicated, national-law aspects, proportionality and contestation angles.
  5. Drafting and filing the challenge where available, with evidence and structured reasoning.
  6. Remediation plan: concrete measures, owners, deadlines and documentation to demonstrate compliance progress.
  7. Multi-party coordination: controllers/processors/vendors alignment to avoid gaps and contradictory narratives.
  8. Follow-up support: responding to authority requests and implementing compliance documentation (without outcome guarantees).

Useful documents & information for the first assessment

DocumentWhy it mattersNotes
ANSPDCP sanction decision/minute + annexesCore findings, legal basis, measures, fine amount and deadlinesSend full copy and service proof if available
Correspondence with ANSPDCP (requests, answers)Shows what was asked, what was provided and whenInclude registry numbers and email headers where possible
Privacy notices, policies and internal proceduresCore compliance layer for transparency and accountabilityProvide versions applicable at the relevant time
Records of processing (RoPA) and DPIA (if applicable)Supports legal basis, purpose limitation and risk approachEven partial drafts can help build the remediation plan
Vendor contracts (DPA), subprocessor lists and role allocationClarifies controller/processor responsibilities and technical measuresCritical in group/vendor chains
Security evidence (logs, incident reports, access control settings)Key for breach/integrity and technical measures findingsPreserve originals and metadata where possible
Short timeline (1–2 pages)Organises facts for challenge and remediationWho, when, what processing, what systems, what decisions

Risks & common mistakes

  • Missing deadlines because the service date was not verified.
  • Providing incomplete sets of documents or mixing versions from different periods.
  • Unclear role allocation (controller vs processor) across vendors or group entities.
  • Focusing only on legal arguments while ignoring technical evidence and timelines (or vice versa).
  • Implementing ad-hoc measures without documenting them, making compliance hard to prove.
  • Overlooking data-subject requests handling and response logs.
  • Using generic policies that do not match actual processing and systems.

FAQ

What is the deadline to challenge an ANSPDCP fine?

Deadlines depend on the legal nature of the act and on service; the practical step is to confirm the service date and determine the applicable procedural route based on the decision you received.

Can we work on a remediation plan while challenging the sanction?

Yes, in many situations the remediation track can run in parallel; it helps reduce operational risk and supports consistent documentation, regardless of litigation outcomes.

What documents are most important for a first GDPR assessment?

The sanction decision/minute, authority correspondence, the privacy notices/policies in force at the time, RoPA/DPIA where applicable, vendor DPAs and a clear processing timeline are typically the core.

How do we handle controller vs processor responsibilities in a vendor chain?

Role allocation must be proven by contracts and actual practices; mapping data flows and responsibilities is usually the starting point for both litigation and remediation.

Can technical evidence (logs, settings) influence the case?

Yes, many findings relate to security and accountability; preserving and presenting technical records can be decisive when the authority alleges inadequate measures.

Do we need to notify data subjects or the authority after an incident?

Notification obligations depend on the incident facts and risk assessment; a documented incident timeline and technical analysis are needed to assess obligations and demonstrate decision-making.

Contact

For a first assessment, send the ANSPDCP decision/minute and annexes plus a short description of the processing context and timeline. You will receive an outline of reasonable next steps and procedural options, along with a proposal for a practical remediation plan.

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Relevant internal links

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