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What happened to the passwords?
The DPC’s decision concerned two incidents involving passwords logged in plaintext from Facebook Lite. The incidents were identified on 7 January and 31 January 2019; the second was described in the decision summary as much larger in scale. The DPC said they involved tens of millions of EU users.
Meta told the regulator that it ordinarily used cryptographic and encryption techniques to store passwords and did not store the individual characters making up a password. The DPC’s findings concerned the specific logging incidents, not a claim that all Meta passwords were routinely stored in plaintext.
Code changes made in November and December 2018 were later identified as the cause of the inadvertent logging. Meta discovered the first incident during an internal security review and the second later that month. It informed the DPC on 21 March 2019, and the regulator opened an own-volition inquiry on 24 April 2019. The DPC announced its decision on 27 September 2024.
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Why did internal access count as a personal data breach?
The GDPR defines a personal data breach in Article 4(12) to include a security breach leading to unauthorized access to or disclosure of personal data, as well as loss, alteration or destruction. The DPC concluded that each incident met that definition. Its reasoning did not depend on an outside attacker: passwords available to employees in plaintext could expose account credentials internally and could enable accounts to be linked with unencrypted passwords.
Passwords that can open social-media accounts are particularly sensitive because access may reveal or enable access to personal information. DPC Deputy Commissioner Graham Doyle said: “It is widely accepted that user passwords should not be stored in plaintext, considering the risks of abuse that arise from persons accessing such data. It must be borne in mind, that the passwords the subject of consideration in this case, are particularly sensitive, as they would enable access to users’ social media accounts.”
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Which GDPR obligations did the DPC find Meta infringed?
The regulator found separate failures in breach handling and in security safeguards:
- Notification — Article 33(1): Meta did not notify the DPC without undue delay and within 72 hours after discovering the second incident.
- Documentation — Article 33(5): Meta failed to document both personal data breaches.
- Security — Articles 5(1)(f) and 32(1): Meta failed to apply appropriate technical and organisational measures to protect the data.
On security, the decision examined a sanitisation framework intended to remove likely sensitive information before logging. That framework was not applied directly to the Facebook Lite server from which the passwords were logged. The DPC said applying it there would have provided a higher level of security and viewed its absence, in the circumstances, as indicative of a serious and systemic failure.
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How was the €91 million penalty divided?
The DPC imposed a reprimand and three administrative fines. The amounts correspond to distinct GDPR obligations:
| Finding | GDPR provision | Fine |
|---|---|---|
| Failure to notify the DPC within the required period | Article 33(1) | €8 million |
| Failure to document the incidents | Article 33(5) | €8 million |
| Failure to apply appropriate security measures | Articles 5(1)(f) and 32(1) | €75 million |
| Total administrative fines | — | €91 million |
The total is the sum of those three fines; the reprimand was an additional corrective measure, not part of the €91 million.
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How did the decision become final?
The DPC adopted its decision on 26 September 2024 and notified Meta. As lead supervisory authority, it used the GDPR’s Article 60 cooperation process, circulating a draft to other concerned EU/EEA supervisory authorities in June 2024. The DPC’s announcement says no objections were raised; the decision page records that four comments were received and considered alongside Meta’s final submission. The DPC publishes the inquiry decision and summary.
What the ruling means—and what it does not establish
The decision illustrates that an organization’s breach duties are not limited to incidents involving an external hacker. Internal availability of sensitive data can meet the GDPR’s breach definition, while notification and documentation are distinct duties from the obligation to secure the data in the first place.
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The DPC’s published findings establish internal availability and the regulatory conclusions described above. They do not establish that an outside attacker obtained or misused the passwords. The sources cited here also do not establish whether Meta appealed or whether later proceedings changed the decision’s status.
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