Precedent corpus / DPC (Ireland)
TikTok Technology Limited
DPC (Ireland) case IN-21-9-2, decided . EUR 530M.
We have not checked whether this decision was appealed. This is not a statement that no appeal exists.
No ConsentMark grade rests on this decision. It is published here because it is relevant enforcement, not because it bears on what a browser does before consent.
What the regulator decided
TikTok transferred EEA user data to the People's Republic of China without verifying that the protections offered by Chinese law were essentially equivalent to those under EU law, breaching Article 46(1) GDPR; and failed to inform users about the transfers and the remote access by personnel in China, breaching the transparency obligation in Article 13(1)(f) GDPR.
Primary source
Regulator-owned URL. Quote this in legal briefs and academic citations.
https://www.dataprotection.ie/sites/default/files/uploads/2025-10/Inquiry%20into%20TikTok%20Technology%20Limited%20April%202025.pdfArchived snapshot
Wayback Machine snapshot of the primary source. Use this when the regulator URL might be refactored or expire.
https://web.archive.org/web/20260506173624/https://www.dataprotection.ie/sites/default/files/uploads/2025-10/Inquiry%20into%20TikTok%20Technology%20Limited%20April%202025.pdfConsentMark interpretation
Operator-readable note on how this case shapes the ConsentMark scanner narrative. Not a legal opinion; cites the primary source.
Distinct from IN-21-9-1 (the September 2023 children's design-patterns case). Composite fine is EUR 485M (Art 46(1)) plus EUR 45M (Art 13(1)(f)). Cite when the scanner narrative needs the precedent for transparency about international transfers and remote access by third-country personnel.
Verification trail
Checked against the primary source on 27th May 2026. Next review 27th November 2026.
Cite this case
@misc{consentmark-precedent-dpc-in-21-9-2,
author = {{ConsentMark}},
year = {2025},
title = {DPC (Ireland) IN-21-9-2 - TikTok Technology Limited},
howpublished = {\url{https://www.consentmark.com/precedent/dpc-in-21-9-2}},
note = {ConsentMark methodology v7.8.1}
}ConsentMark. (2025, April 30). DPC (Ireland) IN-21-9-2 - TikTok Technology Limited. Methodology v7.8.1. https://www.consentmark.com/precedent/dpc-in-21-9-2[DPC (Ireland) IN-21-9-2 - TikTok Technology Limited - ConsentMark](https://www.consentmark.com/precedent/dpc-in-21-9-2)DPC (Ireland) IN-21-9-2 - TikTok Technology Limited - ConsentMark, 2025-04-30, methodology v7.8.1, https://www.consentmark.com/precedent/dpc-in-21-9-2