Asociacion de Medicos Democratas fined EUR 10k

On 07/Jan/2020, Asociacion de Medicos Democratas received a privacy fine of EUR 10,000. The enforcement authority (Spanish Data Protection Agency) has cited these legal provisions in imposing the fine on Asociacion de Medicos Democratas: Article 6 GDPR/ GDPR/


Date of enforcement action:
Jurisdiction: Fine imposed:
Spain Flag for Spain, which is the jurisdiction taking enforcement action EUR 10,000 (US$11,000)
Defendant company or entity: Industry segment:
Asociacion de Medicos Democratas Associations / Non-profit /

Case summary

Asociacion de Medicos Democratas, translated roughly into English as the “Democratic Medical Association”, was fined EUR 10,000 by the Spanish Data Protection Agency on 7/Jan/2020. The Association had communicated repeatedly with doctors by email in 2018 but had not obtained their consent, as required by Article 6 of the GDPR, in order to do so. The regulator cited some 17 email communications in its decision, including those titled “The New School”, “Benefits to the Medical Budget”, “Last Step to Reduce the Fee” and “A Reduction of the School Fee Up To EUR 30 Only Depends On You”.

While noting that there was “no record that the entity had acted maliciously”, the Spanish regulator did remark that the circumstances revealed “a serious lack of diligence”. The regulator also noted that tacit consent would not be sufficient consent under the GDPR.

The Spanish Data Protection Agency acted on complaints that it had received in taking action against Asociacion de Medicos Democratas. The fine of EUR 10,000 was imposed on the basis that the Association “was not a large entity” but rather was a non-profit association.

Applicable legal provisions

Enforcement information

Enforcement authority: Type of enforcement action:
Spanish Data Protection Agency Flag for Spain, which is the jurisdiction taking enforcement action Penalty notice
Subject to appeal?
Yes (an administrative appeal can be filed against the decision)

File or case number


Cite this fine in your work

Data Privacy Fines Index. (2020-01-28 05:53) Asociacion de Medicos Democratas fined EUR 10k. Retrieved from

Entry last updated: 2020-01-28 06:07 GMT.