nanog mailing list archives

Re: Whois vs GDPR, latest news


From: Michel 'ic' Luczak <lists () benappy com>
Date: Sat, 26 May 2018 20:36:15 +0200



On 26 May 2018, at 20:28, Seth Mattinen <sethm () rollernet us> wrote:



On 5/26/18 8:15 PM, Michel 'ic' Luczak wrote:
The two levels depend on the nature of the infringement, but it says clearly “up to 10M” (or 2% of your worldwide 
revenue, whichever is bigger) for the “less serious” infringements. So no, there is no minimum fine actually.


To me that says the fine is 10M if your 2% is lower than 10M. Or it wasn't originally written in English and the 
translation is flawed.

Original text from EU Commission:
"Infringements of the following provisions shall, in accordance with paragraph 2, be subject to administrative fines up 
to 10 000 000 EUR, or in the case of an undertaking, up to 2 % of the total worldwide annual turnover of the preceding 
financial year, whichever is higher”

-> Administrative fines _up to_ 10M (or 2% if your 2% is higher than 10M). 

It’s a cap, not a minimum. 




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