Datadata-law#40F2FE#0A7C8A

AEPD Defence

Defence in AEPD sanctioning proceedings, from the notice of initiation to the final decision.

Submissions and the decision on the fine reduction, within the deadline.

§ 1

Approach

In an AEPD case the first decision is whether to pay at a reduction, and it is taken before a single submission is written.

Pay or defend

Acknowledging liability and paying before the decision reduces the fine, and each reduction gives up the right to contest it. We run the numbers with the file in front of us before the deadline expires.

Submissions count

What is not put forward in the procedure arrives too late at the Audiencia Nacional. Submissions are drafted with the appeal that may follow in mind.

Data and procedure

The case is won by reading the data processing and the sanctioning procedure at the same time. That is why the two of us handle it together.

§ 2

Engagement

Companies under investigation
Submissions and the decision on the fine reduction, within the deadline.
€1,500 + VAT
Per case timetable

El importe exacto se cierra en la hoja de encargo antes de pagar, con los gastos previsibles incluidos. Si el encargo se alarga, no pagas más.

§ 3

Process

How the engagement unfolds

Pre-Consultation NDA

A unilateral confidentiality agreement signed by PASSAS before the video consultation, available at no additional cost on request. It binds the firm alone — no signature is required from the client — and adds an explicit contractual layer on top of the professional secrecy obligations inherent to the practice of law.

Initial Consultation

A 60-minute working session by video call in which we analyse your situation, your specific needs and our ability to help you. We assess whether we can take on the matter and give you the fixed price in advance. You can book it directly through the Google Calendar link on our website and pay €90 by Stripe.

Strategy Memorandum

Document produced once the engagement is accepted, setting out the agreed legal strategy for the matter. It specifies the procedural approach, the main arguments, the evidence to be deployed and the objectives of the proceedings. It is the roadmap for the case and the reference point for any subsequent tactical decision.

Submissions

Written submissions against the notice of initiation and against the proposed decision in the sanctioning procedure, with the evidence that supports them. Before drafting them we decide whether to take the reductions for acknowledgement or voluntary payment, because accepting them narrows or closes any later defence.

Case Monitoring

Ongoing attention to the matter between the main steps: deadline control, procedural or administrative follow-up, response to requests for correction and management of court notifications. The client hears from us each time there is a development in the file, and never has to ask in order to know what is happening.

§ 4

Team

Who handles it

Guillermo Passas Varo, founding partner of PASSAS

I see legal practice as a discipline of precision. I work where the law meets technology and cross-border operations, and I read code and contracts with the same attention. Before accepting an engagement I tell you whether it is worth pursuing and what it costs, at a fixed price.

David Sánchez Lorenzo, of counsel at PASSAS

I work where economic law meets technology: litigation, contracts and artificial intelligence systems. I am drawn to the ground where the rules are still being written, and I have brought that same rigour to litigation since my first year in practice.

§ 5

Questions

What people ask before instructing this service

How long do I have to respond?

As a rule, ten working days from the notice of initiation, and the same again when the proposed decision arrives. It is worth booking the Virtual Consultation as soon as the notification lands.

Should I pay at a reduction?

It depends on how strong the defence is and on the amount. The reductions for acknowledgement and for voluntary payment can be combined, but they require waiving administrative appeals and, in practice, close off any later challenge. We decide it with you once the file has been read.

Does it include an appeal to the Audiencia Nacional?

The engagement ends with the decision in the procedure. If an appeal is worthwhile, proceedings before the Audiencia Nacional are a new engagement, with their own proposal and invoice.

How much does it cost?

From €1,500 + VAT. The exact figure is fixed in the engagement letter before you pay and never exceeds 20% of the proposed fine, so the engagement fits when at least €7,500 is at stake.

Book your Virtual Consultation with a lawyer. Today.

60 minutes on Google Meet with a qualified lawyer specialising in artificial intelligence, data, litigation or international law. €90 including VAT, deducted from the first invoice if we take on your matter. You leave with legal judgement and a fixed price for whatever comes next.

Choose your lawyer and a time in the calendar. No forms first, no sales calls.