GREECE Law and Practice Contributed by: Anastasia Dritsa, Elisabeth Eleftheriades, Vicky Kriketou, Irene Kyriakides, Ioanna Kyriazi, Victoria Mertikopoulou, Claire Pavlou and Panagiotis Pothos, Kyriakides Georgopoulos Law Firm
HDPA are binding but may be challenged before the Council of State (see also below). Enforcement trends Recent enforcement practice indicates an increas - ing focus on high-risk areas, including employment- related processing and data breaches. Violations of data subject rights remain a consistent priority, with particular emphasis in the past year on the right of access. Looking ahead, greater emphasis is expected on transparency obligations, in line with co-ordinated enforcement actions of the European Data Protection Board and the participation of the HDPA therein. Other relevant authorities The Hellenic Authority for Communication Security and Privacy is responsible for safeguarding the con - fidentiality of communications. It issues regulations, conducts audits, and investigates complaints, par - ticularly in relation to telecommunications and lawful interception. The Hellenic Cybersecurity Authority is responsible for cybersecurity oversight. It supervises the implementa - tion of the NIS2 framework and co-ordinates incident reporting at the national level. In the financial sector, additional supervisory respon - sibilities arise under the Digital Operational Resilience Act. These are exercised by authorities such as the Bank of Greece and the Hellenic Capital Market Com - mission, which oversee digital operational resilience and ICT risk management. Judicial proceedings • Civil Law – Compensation Claims: Individuals whose data protection rights are infringed may seek judicial protection before the civil courts. Claims may include compensation for both mate - rial damage (eg, financial loss) and non-material damage (eg, distress or reputational harm). Courts assess compensation on a case-by-case basis, considering factors such as the nature and seri - ousness of the infringement and the impact on the individual.
• Criminal Proceedings: Greek law provides for crimi - nal liability in cases of serious violations of data protection legislation. Criminal proceedings are conducted before the competent criminal courts, either following a complaint by the affected indi - vidual or upon initiation by the public prosecutor. • Administrative Proceedings: Decisions of the HDPA are binding on the parties concerned; however, parties whose rights or interests are affected may challenge such decisions before the Council of State. Explanatory Note: The above avenues of redress operate independently; none is contingent upon the initiation of another. 9. Looking Forward 9.1 Upcoming Legal Reforms Merger Control: More Interventionist Enforcement and Procedural Modernisation The most significant development in Greek merger control is not legislative but enforcement-driven. Recent cases suggest that the HCC is increasingly willing to subject transactions affecting concentrated domestic markets to rigorous scrutiny and, where necessary, require far-reaching remedies or allow transactions to be abandoned. This trend was illus - trated by the proposed EUR217 million acquisition by Allwyn International of a controlling stake in Novibet’s parent company, Logflex MT Holding. Following the issuance of a Statement of Objections in December 2025, the parties abandoned the transaction in March 2026 (HCC Decision No 904/2026). The HCC’s con - cern was the elimination of OPAP’s only meaningful competitor in the Greek online betting market. This follows the HCC’s prohibition of the Alphabet/Delta transaction in July 2025, its first merger prohibition in over two decades. Parties considering acquisitions in concentrated sectors, particularly involving digital markets or the elimination of a key competitive con - straint, should expect rigorous scrutiny. At the same time, Greece is continuing to modernise its merger control framework. Recent amendments have sim - plified certain procedural aspects of the notification process and further aligned domestic practice with EU standards. An additional point to watch will be
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