Why was Toyota Bank Fined and how much?
In early 2025, Toyota Bank Polska S.A. was hit with a significant fine by the Polish Data Protection Authority (UODO) for breaches of the General Data Protection Regulation (GDPR). The bank was penalised to the tune of PLN 576,220 (approximately £115,000) for two major failings:
Lack of Independence of the Data Protection Officer (DPO):
Toyota Bank’s appointed DPO reported directly to the head of the security department, the same person responsible for managing data processing. This structure posed a clear conflict of interest, violating GDPR Article 38, which mandates that a DPO must operate independently and without interference.
Failure to Document Profiling Activities:
The bank engaged in automated profiling of customers to assess creditworthiness, yet failed to document this in its high-risk processing in its Records of Processing Activities (RoPA) or carry out a proper Data Protection Impact Assessment (DPIA), as required by law.
A DPIA helps identify and reduce data protection risks in high-risk processing like profiling. An independent DPO ensures this is done properly. TenIntelligence offers independent DPO services and can help with DPIAs to keep your business compliant.
The Critical Role of an Independent DPO under GDPR
GDPR mandates that organisations appoint a DPO who is both independent and free from conflicts of interest. The DPO must be empowered to act autonomously and report to the highest level of management. Failure to ensure this independence, as demonstrated by the Toyota Bank case can result in significant reputational and financial damage.
How TenIntelligence’s Virtual DPO Services Can Protect Your Business?
At TenIntelligence, we offer Virtual Data Protection Officer (DPO) services that provide your organisation with an independent, expert DPO, without the high salary and overheads associated with a full-time in-house role. Here’s how we help:
- True Independence:Our DPO can operate outside your internal reporting structures, ensuring they can offer impartial advice and oversight just as the GDPR intended.
- Expert Compliance Knowledge:We stay up to date with evolving data protection laws such as the UK GDPR, EU GDPR, UAE PDPL, and KSA PDPL and provide proactive guidance to help your organisation remain compliant
- Cost-Effective Compliance:Avoid the cost of recruiting and retaining a full-time DPO. Our virtual model offers premium support at a fraction of the cost.
- Comprehensive Support Services:From developing privacy policies to conducting audits, training staff, and managing DPIAs, our team acts as your trusted compliance partner.
Don’t Risk a Regulatory Breach
Toyota Bank Polska’s experience is a stark reminder of the consequences of overlooking GDPR requirements. By partnering with TenIntelligence, you can confidently delegate your data protection responsibilities to an experienced, independent professional, safeguarding your organisation from legal, financial, and reputational risks.