The European Data Protection Board adopted its final version of the "Guidelines on the calculation of administrative fines following public consultation." The guidelines serve as a resource for EU member states' data protection authorities to "harmonise the methodology" they "use to calculate fines." The guidelines have five steps for arriving at a penalty: accounting for the "number of instances of sanctionable conduct," the starting point of the fine calculation, "aggravating or mitigating factors," maximum fine amount, and "requirements of effectiveness, dissuasiveness and proportionality."
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