White Paper · Compliance Module

Your GDPR Score Is Not a Number — It's a Fine Waiting to Happen.

CNIL €1.7M, AEPD €950K, CPPA $1.35M — three enforcement actions scored article by article. Art. 5, 9, 30, 32. CCPA, NIS2, SOC2, DORA.

April 2026
12 min read
PDF · 8 pages
EN · FR
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Three enforcement actions. Three scores. Article by article.

Each case followed the same pattern: documentation existed, but the data told a different story.

France · Healthcare Software

3 databases. Shared accounts. No encryption at rest.

Systems handling health records with shared credentials, weak passwords, and no encryption. Article 32 violations confirmed during investigation.

Global score (S013)22 / 100
GDPR Art. 90 / 100
GDPR Art. 320 / 100
Undeclared activities74%
Spain · Identity Verification

890,000 biometric records. No deletion policy.

Facial biometric data — Art. 9 special category. Pre-checked consent boxes. Biometric data retained indefinitely with no deletion schedule.

Global score (S013)14 / 100
GDPR Art. 90 / 100
GDPR Art. 5 — Retention0 / 100
Legal basisInvalid
California · Retail Distributor

2.3M records. No opt-out. No vendor contracts.

No opt-out mechanism in data flows. 0 of 7 vendors with compliant data processing addendums. No consent records for third-party sharing.

Global score (S013)31 / 100
CCPA opt-out0 / 100
Vendor contracts0 / 7
DSAR process40 / 100

What this white paper covers

8 pages. No filler. Scored cases, methodology, and a pricing comparison.

Why declarations fail — what regulators actually check

Every GDPR fine starts with a gap between what was declared and what regulators found. This paper traces the structural reason that gap exists.

Three enforcement actions scored article by article

CNIL €1.7M, AEPD €950K, CPPA $1.35M — each scored article by article. What APOLLO would have surfaced before the investigation started.

Article-level GDPR scoring (A through F)

Not a maturity score. An article-level grade based on actual data: Art. 9 detection, Art. 32 encryption, Art. 30 register completeness — each graded A–F.

Five frameworks in one scan

GDPR by article, CCPA gap analysis, NIS2 posture, SOC2 readiness, DORA digital resilience. One scan, one dashboard — not five questionnaires.

Remediation plan with €/$ impact per action

Each corrective action shows what it fixes, which article it addresses, and the exact penalty reduction if implemented. The DPO sees what each fix is worth.

Pricing comparison: GRC, DPO tools, DSPM vs. APOLLO

GRC at $200K/year, privacy tools at €50K, enterprise DSPM at $500K. What they cover, what they miss. Starter: €2,999/year.

The register existed.
The data told a different story.

A French healthcare software company had policies in place and its processing register documented. When the CNIL investigated, it found shared accounts and 0% encryption on systems handling health records.

APOLLO's scan returned a 74% gap between declared and detected processing activities. Art. 9: 0/100. Art. 32: 0/100. Estimated exposure: €2.1M — before the investigation opened.

“The company had declared its data processing activities. But it had never scanned its own systems to verify whether the technical measures matched the declarations.”

— CNIL investigation findings, 2025
Dimension
Score
Grade
Global Risk (S013)
22 / 100
F
GDPR Art. 9 — Health data
0 / 100
F
GDPR Art. 32 — Encryption
0 / 100
F
GDPR Art. 30 — Register
15 / 100
F
GDPR Art. 5 — Retention
45 / 100
D
Estimated exposure
€ 2.1M
Sources cited in this paper
CNIL Bilan sanctions 2025DLA Piper GDPR Survey 2026CPPA CCPA Fines 2025AEPD FY24ECSO NIS2 TrackerIBM Cost of a Data Breach 2025Forrester/Cyera 2024

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