Search
Contact
19.07.2019 | KPMG Law Insights

Hague hospital fined up to 760,000 euros

Hague hospital fined up to 760,000 euros

The Dutch Data Protection Authority (Autoriteit Persoonsgegevens) has imposed a fine of 460,000 euros on a hospital for failing to protect patient records from unnecessary access in the hospital information system. According to the report, at least 85 hospital employees unnecessarily and unauthorizedly accessed the medical records of a known patient without being involved in the patient’s care.

The regulator made it clear in its press release that the relationship between a healthcare provider and a patient is completely confidential. This also applies within the walls of a hospital. A hospital must therefore take all technical and organizational measures to ensure the security of patient data. Each hospital would need to regularly review who consults which record. This is the only way to take timely action if an unauthorized employee accesses a file.

Patient files should also be technically secured with at least two-factor authentication. Each time a patient record is accessed, a user’s identity would have to be logged by a code or password in combination with a personnel card. Uniform passwords for entire departments or the use of a common user name to avoid having to log in again each time are not permissible.

In order to implement these requirements effectively and as quickly as possible, the supervisory authority is putting the hospital under further pressure: as long as the safety precautions have not been improved, the hospital must pay an additional fine of another 100,000 euros every two weeks, up to a maximum of 300,000 euros. As a result, the hospital faces a maximum fine of 760,000 euros.

Already in October last year, a fine of 400,000 euros was imposed on a hospital in Portugal for a similar violation. The reason for this was also the lack of security of the patient file against access by non-treating medical staff. Even if the national supervisory authorities are in principle free to determine the level of fines, a comparable level of fines must also be expected in Germany for the inadequate security of patient records due to inadequate authorization concepts in hospital information systems.

Explore #more

04.11.2026 | KPMG Law Insights

EUDR: These obligations apply throughout the supply chain – as of 2026

After being postponed twice, the EU Deforestation Regulation (EUDR) is expected to take effect on December 30, 2026. Companies that handle certain products derived…

04.11.2026 | In the media

JUVE: Risks Associated with the Use of AI at the Highest Levels

AI can assist executive boards, supervisory boards, and managing directors in making decisions. However, unverified results can create liability risks. Fraport General Counsel Thomas Stoll…

30.10.2026 | In the media

New Podcast in the Packaging Journal: PWR in Practice—Who Is Liable, Who Pays, and What Are the Current Rules?

The core obligations of the PPWR have been in effect since August 12, 2026. In the Packaging People podcast, Dr. Simon Meyer of KPMG Law…

29.10.2026 | In the media

KPMG and KPMG Law Article in *Betriebs-Berater*: Pitfalls in Customs Law

In light of geopolitical changes, new trade barriers, and more rigorous audits, customs and foreign trade law are increasingly becoming a focus for companies. The…

27.10.2026 | In the media

Op-Ed in Versicherungsmonitor: The Environment Is Finally Becoming a Compliance Risk

With the implementation of the new EU Environmental Criminal Law Directive, the environment is becoming a core area of managerial liability. Managers face reputational damage,…

27.10.2026 | KPMG Law Insights

Federal Court of Justice on the Summary Report: Tax-Exempt but Still a Criminal Offense

Can someone be punished for sales tax evasion even if the sales were subsequently deemed tax-exempt? Yes, says the Federal Court of Justice (BGH) in…

23.10.2026 | KPMG Law Insights

PHP2Shell may trigger legal obligations for companies

Two critical vulnerabilities in the PHP programming language are threatening web applications and digital products worldwide. The Federal Office for Information Security (BSI) has warned…

20.10.2026 | In the media

KPMG Law Guest Column in it daily: The Business Judgment Rule and the Use of AI

The rapid advancement of artificial intelligence presents corporate leadership with diverse and far-reaching decisions. These decisions concern not only the selection and deployment of appropriate…

19.10.2026 | In the media

New articles have been published in PERSONALFÜHRUNG

The current issue of PERSONALFÜHRUNG (10–11/2026) features two articles by female experts from KPMG and KPMG Law. In the article “Will AI Save the Day?…

15.10.2026 | KPMG Law Insights

Faster Building Permits – Legal Options for Businesses

Planning and permitting procedures do not always have to delay construction projects. The law provides several options for expediting the process. To take advantage of…

Contact

Sebastian Hoegl, LL.M. (Wellington)

Senior Manager
Lawyer
Specialist lawyer for IT law
LL.M. (Wellington)

Heinrich-von-Stephan-Straße 23
79100 Freiburg im Breisgau

Tel.: +49 761 769999-20
shoegl@kpmg-law.com

Maik Ringel

Senior Manager

Münzgasse 2
04107 Leipzig

Tel.: +49 341 22572563
mringel@kpmg-law.com

© 2026 KPMG Law Rechtsanwaltsgesellschaft mbH, associated with KPMG AG Wirtschaftsprüfungsgesellschaft, a public limited company under German law and a member of the global KPMG organisation of independent member firms affiliated with KPMG International Limited, a Private English Company Limited by Guarantee. All rights reserved. For more details on the structure of KPMG’s global organisation, please visit https://home.kpmg/governance.

KPMG International does not provide services to clients. No member firm is authorised to bind or contract KPMG International or any other member firm to any third party, just as KPMG International is not authorised to bind or contract any other member firm.

Scroll