7 GDPR Mistakes That Could Cost Your Company Millions in 2025

GDPR fines reached over €1.5 billion in total since 2018. In 2024 alone, companies paid hundreds of millions in penalties. The largest single fine to date was €1.2 billion. Yet most organizations still make the same preventable mistakes.

This guide reveals the 7 most common GDPR violations that trigger fines, with real examples from recent enforcement actions. You'll learn what triggers penalties, how to spot vulnerabilities in your organization, and step-by-step fixes you can implement today.

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Data protection authorities across the EU are increasing enforcement activity. Since GDPR took effect in May 2018, the number and size of fines have grown significantly each year.

Largest GDPR Fines to Date

The largest GDPR fine issued was €1.2 billion to Meta (Facebook) in 2023 for unlawful data transfers. Other major fines include:

• €746 million to Amazon in 2021 for cookie consent violations
• €405 million to Instagram in 2022 for children's privacy violations
• €345 million to WhatsApp in 2023 for transparency violations
• €265 million to Google in 2022 for cookie consent issues

These fines show that data protection authorities don't spare large or small companies. Every organization processing personal data must comply with GDPR.

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Under Article 83 of GDPR, the most serious violations can result in fines up to €20 million or 4% of global annual turnover, whichever is higher.

Data protection authorities consider several factors when determining fine amounts:

• Nature and severity of violation: How serious is the breach and how many people are affected
• Intentional or negligent: Was the violation intentional or due to negligence
• Mitigation measures: Did the company take steps to prevent violations
• Violation history: Does the company have previous fines
• Cooperation with authority: How did the company cooperate during investigation

GDPR Fine Categories

GDPR fines fall into two categories:

Category 1 - Up to €10 million or 2% of annual turnover:

• Inadequate technical and organizational measures
• Failure to maintain records of processing activities
• Incorrect appointment of DPO (Data Protection Officer)
• Failure to conduct data protection impact assessments

Category 2 - Up to €20 million or 4% of annual turnover:

• Violation of basic data processing principles
• Unlawful obtaining of consent
• Failure to handle individual rights requests
• Unlawful transfer of data to third countries

Based on analysis of fines issued across the EU, most violations come from these seven mistakes.

1. Improper Consent Management

The most common mistake is improper obtaining and management of consent for processing personal data. Companies often:

• Request consent for all purposes at once
• Don't allow easy withdrawal of consent
• Don't maintain records of when consent was given
• Use pre-checked checkboxes (which isn't valid consent)

Example from practice: A company received a €30,000 fine for using cookies without valid consent. The company had a pre-checked checkbox that didn't meet GDPR requirements.

2. Failure to Handle Individual Rights

GDPR grants individuals eight fundamental rights. Companies often fail to respect these rights:

• Right of access
• Right to rectification
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object
• Rights related to automated decision-making
• Right to be informed about breaches

3. Failure to Maintain Records of Processing

Every company that processes personal data must maintain records of processing activities. Most companies don't maintain these records or maintain them incorrectly.

Records must contain:

• Purpose of data processing
• Categories of individuals whose data is processed
• Categories of personal data
• Data recipients
• Data retention periods
• Technical and organizational security measures

4. Improper Data Breach Handling

If a data breach occurs that poses a risk to individuals' rights and freedoms, you must notify the supervisory authority within 72 hours. If the risk is high, you must also notify affected individuals.

Most companies:

• Don't recognize what constitutes a data breach
• Don't notify authorities on time
• Don't notify individuals when required
• Don't maintain breach records

5. Improper Vendor Management

If you share personal data with vendors (e.g., hosting, marketing agencies), you must have data processing agreements. Most companies don't have these agreements or have them incorrectly drafted.

Example from practice: A company shared personal data with a marketing agency without a valid data processing agreement. The authority issued a fine because the company didn't ensure the vendor complied with GDPR requirements.

6. Inadequate Security Measures

Companies must implement appropriate technical and organizational security measures. Many companies have:

• Weak passwords or no password policies
• No encryption for sensitive data
• No access controls
• No regular security audits
• No employee training on data security

7. Unlawful Data Transfers

Transferring personal data outside the EU without proper safeguards violates GDPR. Common mistakes include:

• Transferring data to countries without adequacy decisions
• Not using Standard Contractual Clauses (SCCs) when required
• Not conducting transfer impact assessments
• Transferring data through cloud services without proper agreements

Ready to implement GDPR compliance? Browse our compliance courses that include practical guidance on implementing all necessary processes in your organization.

Here's a practical guide to protect your company from GDPR fines.

Step 1: Conduct a Compliance Assessment

First, assess where your company currently stands regarding GDPR requirements. Conduct an internal audit or hire an external expert.

Check:

• Do you have records of processing activities
• How do you obtain consent for data processing
• How do you handle individual rights requests
• Do you have data protection measures
• Do you have agreements with vendors

Step 2: Implement a Consent Management System

Implement a system that allows you to:

• Obtain valid consent for each processing purpose
• Easily withdraw consent
• Maintain consent records
• Distinguish between different types of consent

Step 3: Establish Processes for Handling Individual Rights

Establish processes that allow you to respond to individual requests within 30 days. This includes:

• System for receiving requests
• Process for verifying individual identity
• Process for collecting and preparing data
• Process for deleting data when required

Step 4: Implement Data Protection Measures

Implement technical and organizational data protection measures:

• Data encryption
• Access controls
• Regular security audits
• Employee training on data protection
• Data breach response plan

Step 5: Ensure Vendor Agreements

Ensure all vendors that process personal data have valid data processing agreements. The agreement must contain:

• Purpose of data processing
• Type of data being processed
• Vendor obligations
• Data protection measures
• Rules for return or deletion of data

Step 6: Establish Data Breach Response Procedures

Create clear procedures for:

• Detecting data breaches
• Assessing breach severity
• Notifying supervisory authority within 72 hours
• Notifying affected individuals when required
• Documenting all breach incidents

Step 7: Train Your Staff

Provide GDPR training to all employees who handle personal data. Training should cover:

• What personal data is
• How to handle data securely
• How to recognize data breaches
• How to respond to individual rights requests
• Your organization's data protection policies

If you receive a GDPR fine from a supervisory authority, you have the right to appeal. However, it's important to understand the process and your options.

Appeal Process

You typically have 30 days to appeal a fine. You can submit an appeal:

• In writing to the supervisory authority
• By email to the authority's official address
• Through official online channels

In your appeal, you must explain why you believe the fine is unjustified. You can attach evidence supporting your appeal.

Fine Reduction

Authorities may reduce fines if:

• The company cooperated during investigation
• The company took measures to correct violations
• The company has no previous fines
• The fine would represent a disproportionate burden

GDPR fines are increasing across the EU. Companies have paid over €1.5 billion in total fines since 2018. The largest single fine was €1.2 billion.

Most fines come from seven main mistakes:

• Improper consent management
• Failure to handle individual rights
• Failure to maintain records of processing
• Improper data breach handling
• Improper vendor management
• Inadequate security measures
• Unlawful data transfers

Key takeaways:

• Conduct a compliance assessment of your company
• Implement a consent management system
• Establish processes for handling individual rights
• Implement data protection measures
• Ensure vendor agreements
• Establish data breach response procedures
• Train your staff

The best way to avoid GDPR fines is to be proactive. Don't wait for a supervisory authority to audit your company. Conduct a compliance assessment today and implement necessary measures.

Ready to take action? Start with a compliance assessment this month. Identify your vulnerabilities, implement the fixes outlined in this guide, and establish ongoing compliance monitoring.

Need help? Browse our compliance courses or contact our team for expert guidance.