Data Protection & GDPR Compliance in Greece

introduction

What Makes Greece Different

The GDPR is a regulation, not a directive – it applies uniformly across the EU. But it contains more than 50 “opening clauses” where member states can legislate differently. Greece has exercised several of these, creating rules that foreign businesses often don’t anticipate.

Employee data

Law 4624/2019 restricts when employers can rely on employee consent as a legal basis for processing. Because of the inherent power imbalance in employment, consent must be genuinely free – and Greek law requires that assessment to account for the employee’s dependency on the employment contract and the specific circumstances under which consent was given. Consent must be clearly separated from the employment contract itself. In practice, this means most workplace data processing in Greece should be grounded in legitimate interests or contractual necessity, not consent. Processing through CCTV in the workplace is permitted only for safety and security purposes – never for employee monitoring or performance assessment.

Children’s data

Greece has set the age of digital consent at 15 (the GDPR default is 16). Below that age, processing requires parental or guardian consent.

Genetic data

Greece has imposed a complete prohibition on processing genetic data for health and life insurance purposes – going beyond the GDPR’s general restrictions on special categories of data.

Public authorities

Public bodies in Greece cannot rely on consent as a legal basis for processing. They must identify an alternative basis under Article 6 GDPR.

Video surveillance

HDPA Directive 1/2011, read together with Law 4624/2019 and the GDPR, governs the use of CCTV systems. Surveillance is permitted only for the protection of persons and property. Footage can be transmitted to police authorities upon request, but the data subject must be informed. Retention periods, signage requirements, and access rights are all regulated – and the HDPA has actively enforced these rules with fines.

safeguard your business

Key topics we cover

Lawful basis

consent/contract/legal obligation/vital interests/public task/legitimate interests

Children’s data

and age gating

Special category data

health, biometrics, beliefs, sexual orientation

Marketing

email/SMS, soft opt-in where applicable, unsubscribe flows

Analytics/ads

consent for cookies; server-side tagging; IP truncation

HR data

recruitment, payroll, references, CCTV at workplace

AI & profiling

transparency, purpose limitation, human oversight

Data retention

justify, minimize, delete

Security Measures

access control, encryption, backups, vendor oversight

The HDPA: How Greece Enforces

The Hellenic Data Protection Authority is a constitutionally established independent authority with investigative and sanctioning powers. It handles complaints, conducts audits (including remote website audits for cookie compliance), and imposes administrative fines.

Fine levels in practice. The HDPA can impose fines up to €20 million or 4% of global annual turnover for private entities, and up to €10 million for public bodies. In practice, fines have ranged widely: €20 million against Clearview AI for unlawful facial recognition processing of Greek citizens’ data; nearly €3 million against Hellenic Post (ELTA) after a cyber-attack exposed data of up to 5 million individuals; €9.25 million combined against major telecom providers for inadequate technical and organisational measures and data leakage; €400,000 against the Ministry of Internal Affairs for unauthorised transfer of voter data; and smaller but consistent fines against banks, employers, and service providers for failing to satisfy data subject access requests, conducting unsolicited marketing, and inadequate breach notification.

Enforcement focus areas. The HDPA has been particularly active on unsolicited marketing communications (SMS, telephone), data subject access rights (especially delays and non-cooperation), data breach notification failures, video surveillance compliance, and cookie consent – where remote audits of controllers’ websites have found widespread non-compliance, though formal enforcement actions are still building.

Criminal liability. Under Law 4624/2019, unauthorised processing and unauthorised disclosure of personal data are criminal offences punishable by up to 20 years’ imprisonment and fines up to €300,000. This is separate from the HDPA’s administrative fining power and applies regardless of intent – negligent violations can trigger criminal exposure.

BREACH NOTIFICATION

The basic GDPR rule applies: notify the HDPA within 72 hours of becoming aware of a breach that poses risks to individuals’ rights. If the breach poses high risk, affected individuals must also be notified directly.
In Greece, the HDPA and the Hellenic Authority for Communication Security and Privacy (ADAE) share jurisdiction over breach notifications – the ADAE handles breaches involving electronic communications networks and services under Law 3471/2006 (the ePrivacy Directive transposition).

Between mid-2023 and early 2024, 167 data breach incidents were notified to the HDPA. Given the size of the Greek market, this is a relatively high rate – and the HDPA has not hesitated to fine organisations that fail to notify or that delay notification.

CROSS-BORDER DATA TRANSFERS

Transfers of personal data outside the EEA follow the standard GDPR framework: adequacy decisions, Standard Contractual Clauses, or Binding Corporate Rules. BCR approvals in Greece must be submitted through the HDPA’s web portal (in Greek), and in practice, the approval process takes approximately three months.

For foreign businesses with Greek operations, the practical issues are typically structuring intra-group data flows to and from Greece, ensuring processor agreements with Greek service providers meet both GDPR and Law 4624/2019 requirements, and navigating the HDPA’s procedures for transfer impact assessments and approvals.

HOW WE HELP

We advise on GDPR compliance for businesses operating in Greece, with particular focus on the areas where Greek law creates additional or different obligations. This includes structuring lawful processing for employee data, customer data, and marketing activities under Greek rules; advising on video surveillance compliance for businesses with Greek premises; responding to HDPA investigations, complaints, and audit requests; handling data breach notification to the HDPA and affected individuals; drafting and reviewing data processing agreements, privacy policies, and internal compliance documentation; and advising on data protection aspects of M&A transactions, employment restructuring, and cross-border data flows.

Contact us if you need GDPR advice specific to Greece. The regulation is EU-wide, but the compliance questions that actually cause problems are almost always local.

Services

Our 6-step roadmap

01

Kickoff & discovery

products, data flows, tools, markets, and risks.

02

Data mapping

systems, categories, purposes, legal bases; produce RoPA.

03

Gap analysis

measure against GDPR, ePrivacy, and Greek practice.

04

Documents & controls

draft notices, DPA, cookies, SCCs, policies; configure consent tools.

05

Implement & train

deploy banners, forms, intake workflows; train teams; test DSARs.

06

Monitor

quarterly reviews, vendor updates, TRAs, incident drills; optional DPO support.

What you get

YOUR COMPLETE GDPR-KIT

Data mapping & RoPA

(Records of Processing Activities)

Lawful basis framework

+ LIA (Legitimate Interests Assessment) templates

Privacy Notices

website/app/HR; EN & GR

Cookie banner & policy

+ consent mode settings (ePrivacy alignment)

DPAs

(Data Processing Agreement) + sub-processor rules

International transfers

SCCs + Transfer Risk Assessment (TRA) templates

DPIA

(impact assessments) for high-risk processing (AI, biometrics, tracking)

Security baseline

& vendor due-diligence kit (questionnaires, clauses)

Data subject rights

playbook & SLAs (access, deletion, portability)

Retention schedule

+ deletion/archiving procedures

Incident response

72-hour breach plan, notifications, evidence pack

Training

slides + quick-reference guides for teams

Frequently Asked Questions

Contact us today for a free initial discussion

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