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Praxikon

Ruling

Council of State: DPA could fine DPG Media for routinely demanding ID copies, fine halved to 262,500 euros

Date
Status
final
Body
Raad van State, Afdeling bestuursrechtspraak
Reference
ECLI:NL:RVS:2025:4562 (zaaknummer 202305954/1/A3; eerste aanleg ECLI:NL:RBAMS:2023:5074)
Amount
€262,500

What it is about

DPG Media routinely required a copy of an ID document up front from subscribers requesting access or erasure outside its online login environment, without first checking whether a less intrusive method, such as a customer number or email verification, would do. The DPA imposed a 525,000 euro fine in January 2022. In 2023 the Amsterdam District Court found a breach of Article 12(2) GDPR but annulled the fine entirely. The Council of State held that the DPA was entitled to fine, because this was structural policy at a large media company rather than an incident. However, the DPA failed to address the mitigation grounds raised, breaching the duty to give reasons. The Council itself reduced the fine by 50 percent to 262,500 euros, citing among other things the relatively small number of cases, the destruction of copies within a month and the policy change well before the enforcement notice.

What this means in practice

Ask for an ID copy only where you reasonably doubt identity and a lighter method (customer number, email verification, other known data) will not do; a blanket rule of always demanding a copy up front breaches Article 12(2) and the data minimisation principle. State in the request itself that a masked copy is enough and destroy copies quickly. If you raise mitigation grounds, the DPA must address them with reasons; if it does not, the court can reduce the fine itself.

The GDPR articles concerned

Source: Rechtspraak.nlchecked on 15 September 2026

Summary and practical reading by Praxikon. Not legal advice; the source prevails.

Connections

What connects to this development

The counterpart in the other law

Case law8 of 19

Guidelines8 of 12

Enforcement and fines8 of 13

Legislation in motion