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Fonte: EDPB
The investigation revealed that the infringement occurred also because of ineffective monitoring of potential risks. The investigation further revealed other misconduct, but it was the lack of appropriate technical (insufficient safeguards) and organisational measures (on the monitoring of potential risks related to atypical online behaviour) that led to imposing a fine. In determining its amount, however, the President of UODO took account of mitigating circumstances, such as: action taken by the company to put an end to the infringement, good cooperation with the controller and the fact that the company has not breached the personal data protection law before.