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In October 2019, the German Data Protection Authorities (“DPAs”) published guidelines on how they are going to determine the amount of a fine in case of a violation of the GDPR. The guidelines explain the concept applied by the German DPAs when determining an appropriate fine.

According to the press release, the concept was discussed on a pan-European level and may be amended or revised once Europe-wide guidelines are released by the European Data Protection Board. Only recently, the Berlin DPA issued a fine of EUR 14.5 million for unjustified retention of customer data.




Julia Kaufmann is a partner in the Munich office of Baker McKenzie. She has been admitted in Germany since 2006 and in New York, USA, since 2009. In addition to her studies in Germany, Julia obtained her Master of Laws degree at the University of Texas at Austin, USA.


Dr. Michaela Nebel is a partner in the Frankfurt office of Baker McKenzie since June 2011 and was admitted as an attorney to the German bar shortly after. Prior to joining Baker McKenzie she studied law at the University of Passau. She obtained her Doctor of Law degree on a topic related to privacy in the Web 2.0. From July until December 2014 she practiced at the San Francisco office of Baker McKenzie. She is a member of the International Association of Privacy Professionals (IAPP) and since May 2015 a Certified Information Privacy Professional/Europe (CIPP/E) and since May 2017 a Certified Information Privacy Professional/United States (CIPP/US). She is also the author of numerous articles on information technology law, in particular on data protection law and e-commerce law, and the co-author of an English language commentary on the EU General Data Protection Regulation. In 2017/2018, Michaela received several recommendations for data protection law in


Florian Tannen is a partner in the Munich office of Baker McKenzie. He advises on all areas of contentious and non-contentious information technology law, including internet, computer/software and data privacy law. He also has profound experience in the drafting and negotiation of outsourcing and IP-project (in particular SAP-implementations) contracts. Before joining the Firm, Florian worked for two major law firms and a large US-based technology company.