> Fines based on gains and damages, not revenue. That's already the case (cf. article 83(2)). The percentage of revenue thing in articles 83(4) and 83(5) is a

> Fines based on gains and damages, not revenue. That's already the case (cf. article 83(2)). The percentage of revenue thing in articles 83(4) and 83(5) is a cap, not a fixed amount. I don't think anybody was ever fined the maximal amount possible. > And a trebling of damages where noncompliance is shown to be willful. This is taken into account, cf. article 83(2)b. Not a trebling though, it's up to the DPA to decide, and cannot exceed the cap.