A lender with total worldwide annual turnover of £600m commits a serious UK GDPR infringement that falls in the higher band of fines. What is the maximum fine?
The higher maximum is £17.5m or 4% of total annual worldwide turnover in the preceding financial year, whichever is higher (UK GDPR Art 83(5); DPA 2018 s157). 4% of £600m is £24m, which exceeds £17.5m. The lower band is £8.7m or 2%, which would give £12m here.
Stopping at £17.5m without checking whether 4% of turnover is higher.
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