PUODO Inspection Plan for 2026

PUODO inspections in marketing. What will the Office check in 2026?

According to the schedule, the supervisory authority will focus in particular on verifying the legal basis for processing personal data for marketing purposes. This means that a PUODO audit conducted at marketing companies and corporate marketing departments may include an analysis of whether activities such as emailing, customer profiling, or remarketing are based on a truly valid and effective legal basis, primarily the consent of the data subject or the legitimate interest of the controller.

Challenges and risks in the area of marketing

Marketing organizations today face a number of challenges related to personal data processing. The most important of these include:

• Correctly specifying the legal basis for processing - GDPR regulations require a realistic match between the specific marketing purpose and the relevant ground of Article 6 of the GDPR, rather than a mere "declaratory" indication. The controller should assess whether the actions require valid consent or can be based on legitimate interests by conducting and documenting a balancing test.
• Customer profiles and profiling - collecting and analysing data for the purpose of audience segmentation or automatically tailoring marketing messages may carry a high risk of violating the rights of individuals, especially if it is done without an appropriate legal basis or without clear information to the user.
• Transparency in communication with data subjects - the disclosure obligation stipulated in the GDPR obliges controllers to clearly present the purpose and scope of data processing. Insufficient or imprecise disclosure clauses are one of the most frequently cited problems by the Personal Data Protection Office.

Internal Marketing Data Audit. PUODO Plan a signal for change

For marketing companies and departments responsible for communicating with customers in this area, the PUODO's review schedule signals that the coming year may bring increased oversight of personal data practices. In practice, this means conducting internal GDPR compliance audits in advance, streamlining documentation regarding consent and legal bases, and verifying processes related to marketing data processing.

Ignoring these signals can result not only in regulatory enforcement and financial penalties, but also in damage to the company's reputation - especially when customers or consumers feel their privacy has been violated.

Summary - how can we help prepare for PUODO inspections in 2026?

The 2026 inspection plan published by the Office for Personal Data Protection (PUODO) serves as a signal to marketing departments and advertising agencies that it is worth preparing for potential oversight. To avoid significant financial penalties and reputational damage, taking pre-emptive action is crucial.

Do not wait for inspection, stay safe with Crowe experts!

At Crowe Poland, we understand that rapidly changing regulations pose significant challenges for organizations. That is why we offer your company support:

• GDPR compliance audits and reviews - a service for companies that want to be sure that their data processing and protection activities are heading in the right direction;
• GDPR compliance monitoring - a service that will completely relieve your company of the obligation to monitor legal changes.

Our support is directed both to organizations that do not have their own Data Protection Officer (DPO) and to entities that need substantive support for internal legal teams.

Provide your company with peace of mind and security - Contact us