> "effective" = large amount, so company won't do it again Generally true, but it should be read with proportionate as meaning as large as necessary to be effe

> "effective" = large amount, so company won't do it again Generally true, but it should be read with proportionate as meaning as large as necessary to be effective -- if a warning is sufficient to ensure compliance, then the effective clause suggests a fine is NOT warranted. > "proportionate" = relative to revenue _Absolutely_ not - proportionate to the _infringement_. There is no other reading that makes sense here. > "dissuasive" = make them an example so no one else will dare. Dissuasive also encompasses encouraging companies to cooperate with regulators and make a best effort to comply. If they are going to get the maximum fine for a minor breach, even if they made a full effort to comply and merely overlooked something, they are _not_ dissuaded from ignoring the GDPR in its entirety. > So you can bet regulators will go for the full amount. Certainly not. Going for the full amount, regardless of the circumstances and ignoring the factors they MUST consider, is going to result in the fines being overturned by the courts, which undermines their position, doesn't fulfill the purpose of the fine (if the company successfully challenges it), and doesn't fulfill the aims of the GDPR. Ignoring the law to go for the maximum fine would be a terrible decision for a regulator to make, and you can look at the history of enforcement of the DPD to see that regulators _don't_ generally go for the maximum fine.