Services

Inspections & Sanctions

When the Privacy Protection Authority contacts you — with an inspection, a demand for documents or a notice of intent to impose a monetary sanction — we represent you before it. We prepare the answer and the documents, argue against the sanction and ask for the reductions the law allows, and appeal to the court where needed.

Four questions that decide the next step

Where you stand with the Privacy Protection Authority decides what needs doing, and by when.

#QuestionWhy it is decisive
1Has the Privacy Protection Authority opened an inspection, asked for documents or started reviewing your sector?You need an orderly answer, and the documents the law requires you to keep: the database definitions document, the data security procedure and the list of access permissions.
2Have you received a notice of intent to impose a monetary sanction?You have 45 days to make your case, in writing or orally. Without it, the notice becomes a demand for payment.
3Have you received a demand for payment?You can appeal to the Magistrates’ Court within 45 days. The appeal does not stop the payment by itself.
4Did you find a breach yourselves?Stopping it and reporting it on your own initiative earns a reduction in the sanction, if one is imposed.

What we do

We are with you at every stage of the process, from the first answer to an appeal.

StageWhat it covers
Responding to an inspectionPreparing the answer and the documents the Privacy Protection Authority asks for, and attending the meetings with its inspectors.
Your exposureHow high the sanction could go — by the number of people in the database, the type of data and how long the breach lasted — and which reductions apply to you.
The hearingWritten or oral arguments: the facts, the steps you have already taken, and the requests for reduction.
AppealAn appeal to the Magistrates’ Court against a demand for payment.
A correction planSteps that prevent a repeat. They ground a reduction, and they are what the Privacy Protection Authority will check next time.

How it runs

The work runs to the deadlines in the Privacy Protection Authority’s letter.

First call
We read the Privacy Protection Authority’s letter together and mark the deadline.
Scope letter
Deliverables, timetable and terms of engagement, in writing, before work starts.
Collection
The facts, the documents and the steps you have already taken.
Response
The answer to the inspection, or the arguments against the sanction, within the deadline.
Continuation
An appeal if needed, and a correction plan that prevents a repeat.
  1. 1. First call
  2. 2. Scope letter
  3. 3. Collection
  4. 4. Response
  5. 5. Continuation

Questions people ask

What happens when we receive a notice of intent to impose a monetary sanction?

You have 45 days to make your case, in writing or orally. If you do not, the notice becomes a demand for payment. After a demand you pay within 45 days, or appeal to the Magistrates’ Court within 45 days; an appeal does not suspend payment by itself. A sanction on a company is published on the Privacy Protection Authority’s website for four years.

How is a monetary sanction calculated?

By the type of breach: a fixed amount, an amount for each person contacted, or an amount for each person whose data is in the database — doubled for specially sensitive data, and with a minimum. There is no multiplier based on turnover; turnover only caps the sanction, since you may ask that it not exceed 5% of your turnover. Reductions of up to 70% in total are available, among others to a business that stopped the breach and reported it on its own initiative, and to one that took steps to prevent a repeat.

Is the Privacy Protection Authority actually imposing sanctions?

Yes. Among others, it imposed NIS 256,000 for a security incident that was not reported immediately, and NIS 12,000 for an incomplete notice on an online sign-up form and in the privacy policy; in the second case it rejected the argument that the breach was trivial.

Has the Privacy Protection Authority contacted you?