Third-party data breach in Poland – what should your company do under GDPR?
22 October 2026
22 October 2026

Following a third-party data breach in Poland, companies should identify compromised information, secure access and assess financial fraud risks. If personal data under their control is affected, they must evaluate their GDPR obligations. Notification to the Polish Personal Data Protection Office (UODO) is generally required within 72 hours of awareness unless a risk to individuals is unlikely.
In this article:
Not every third-party data breach in Poland constitutes a personal data breach under Article 4(12) of the General Data Protection Regulation (GDPR).
Compromised accounting, invoicing or payroll systems may expose:
Commercial information may require protection against fraud even when GDPR notification obligations do not apply.
Businesses using a compromised system should take five steps:
Article 33(5) GDPR requires controllers to document personal data breaches even when supervisory authority notification is unnecessary.
Under Article 33(1) GDPR, notification must be made without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
The requirements depend on the risk assessment:
Late notifications must include reasons for the delay. Missing information may be submitted in phases.
A provider’s own notification does not automatically fulfil the customer’s obligations as data controller.
On 28 September 2026, Polish invoicing platform Fakturownia identified unauthorised access involving the copying of a substantial portion of its database.
All accounts were affected, although the scope varied. According to the company, approximately 2,250 accounts had all available data from 2022–2026 copied, up to the applicable account-specific cut-off date.
Fakturownia reported the breach to UODO on 29 September 2026 and began issuing individual notifications on 1 October.
Affected businesses should check their exposed records, secure accounts and assess their own GDPR responsibilities.
Article 28 GDPR requires controllers to use processors providing sufficient security guarantees.
Companies should review vendor security arrangements, establish data processing agreements, restrict access permissions and maintain incident response procedures.
Business continuity arrangements are also important where accounting or payroll systems become unavailable.
Failure to comply with obligations under Articles 33 and 34 GDPR, among others, may result in fines of up to EUR 10 million or 2% of total worldwide annual turnover in the preceding financial year, whichever is higher.
Third-party data breach in Poland – what should your company do under GDPR?
If you have any further questions or require additional information, please contact your business relationship person or use the enquiry form on the HLB Poland website.
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