How specifically should the data controller describe the possible consequences of a personal data breach to the data subject?

ANSWER

The data controller is obliged to notify the data subject of a breach if there is a high risk to their rights or freedoms. The notification, pursuant to Article 34(2) GDPR, must contain the elements listed in Article 33(3)(b), (c) and (d) GDPR. These include, among others, a description of the likely consequences of the breach and the measures taken or proposed by the controller to address the breach.

Depending on what data was lost/misplaced, the possible consequences of the breach should be described. Merely stating that a loss of data confidentiality has occurred will not be sufficient. If the medical records contained personal data such as the PESEL number, home address, and date of birth, the possible consequences of the breach include, among others: the risk of taking out loans from non-bank institutions, insurance companies issuing policies without verifying documents, entering into various contracts with service providers without presenting identity documents, e.g. for television or internet services. There are also patient registration systems that operate using only the PESEL number, etc. These are the possible consequences for the data subject. The controller is obliged to specify them depending on what personal data was lost.