The Dutch DPA announces an investigation, what do I do?
Do not panic, do not hide, document everything. AP investigations follow requests or complaints; show that policy and register are in order.
Try this first
- 1Read the notification carefully. Which processing, which period, which documents requested. Reply within the stated timeline.
- 2Assemble a team: DPO (or deputy), legal, plus the owner of the relevant processing. Not the whole board.
- 3Pull together: processing register, DPIA if any, DPAs with processors, privacy notice, security policy, incident register.
- 4Answer honestly. This is not an exam scored on perfection; honest about gaps plus action plan beats cover-up.
- 5Archive everything you shared and when. Expect a follow-up.
When to bring us in
Suspecting a formal order under penalty or an active enforcement procedure? Get legal counsel involved immediately. Not DPO work.
See also
- Does NIS2 apply to my company?Two questions decide it: are you in a listed sector, and do you meet the threshold from Recommendation 2003/361/EC (more than 50 FTE and more than EUR 10M turnover or balance sheet). Below that you are only indirectly in scope, via your customers. The threshold determines whether you are an important or essential entity depending on sector.
- What changes with the Dutch Cyber Security Act?The Cyberbeveiligingswet is the Dutch implementation of NIS2. Track NCSC for the exact effective date and the lower regulations.
- Am I personally liable as a director under NIS2?Yes. The board is accountable for approving and overseeing the cyber measures. Severe negligence can become personal.
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