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First establish whether HDPA notification is required
For a controller for which the Hellenic Data Protection Authority is competent, the guidance requires notification without undue delay and, where feasible, within 72 hours after the controller becomes aware when the reporting-risk threshold is met. The clock is awareness, not the completion of the investigation.
Identify the actual controller/processor roles and competent authority. Greek incorporation and the supplier’s American address do not alone settle cross-border competence. Not every incident is reportable; retain the reasons for the decision and an internal breach record even where authority notification is not required.
Prepare the applicable route while facts develop
Suppose an American helpdesk reports exposed customer tickets to a Greek business. Record when the controller became aware, the known affected data and people, and assess the reporting risk. Where notification is required, prepare the initial notice through the applicable route and supplement it without undue delay as information develops.
The described Greek-established-controller portal uses Taxisnet credentials. Arrange an authorised filer without sharing those credentials with the U.S. provider. The English/email alternative has stated conditions for cross-border or extraterritorial cases and non-Greek-established controllers unable to use Taxisnet; it is not an unrestricted alternative for every Greek controller.
Assess communication to people separately
The high-risk question about informing affected people is distinct from authority notification. Assess that as the investigation continues; filing with HDPA does not answer it.
Scope
- This does not decide competence, reporting risk or every exception for an actual incident. The original data transfer, lawful processing, processor contract and sector-specific duties remain separate.
Next step
Record awareness and assess risk and competence now; if notification is required, use the applicable initial-filing route without awaiting every technical detail.
Sources & review notes
Hellenic Data Protection Authority
Passage, dates and research notes
official-guidance · Risk, awareness clock, initial/supplementary notice and internal record
not later than 72 hours after the controller has become aware of it
Full official English body read. Regulatory notification is risk-based, high-risk individual communication is separate, and even non-notified breaches need an internal record. The guide is limited to a controller for which HDPA is competent; Greek origin alone does not settle lead-supervisory-authority or cross-border competence.
Hellenic Data Protection Authority
Passage, dates and research notes
official-guidance · Greek-established portal route; limited English/email alternative
you must use the taxisnet credentials available to controllers established in Greece
Full official English instructions read. Greek-established controllers use the portal/Taxisnet route. The authority describes English notifications for cross-border or Article 3(2)/(3) cases and an email route for controllers not established in Greece unable to use Taxisnet; this is not a general email substitute for a Greek controller. No portal login, credentials, macro activation or notification was performed.
Detailed rule records (2)
Where HDPA is competent, its guidance describes risk-based supervisory notification without undue delay and where feasible within 72 hours of controller awareness; incomplete information can be provided initially and supplemented. Even a breach not notified must be internally recorded; high-risk individual communication is separate.
Notification of data breachesHDPA instructions require portal submission using Taxisnet credentials available to Greek-established controllers. Its English/email alternative is described for specified cross-border/extraterritorial cases and non-Greek-established controllers unable to use Taxisnet; it is not an unrestricted substitute for the Greek portal.
Submission of a data breach notification to the HDPA Notification of data breachesKeep this reading in your learning library.
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