Result of the resolution: Declaration of breach
Not having the relation of users and not guaranteeing the correct identification and authentication of the users, harms the principle of security of the data and is constitutive of a severe offense. On the other hand, the breach of the duty of secret, it is constitutive of a severe offense. In the last one, not to attend to the requirements for information of the Authority, it also constitutes a severe offense.
Applied articles: 9, 10, 40, 43, 44.3.d, 44.3.h and 44.3.i) LOPD; 91 and 93 RLOPD; 19 of the Law 32/2010.