Garante per la protezione dei dati personali (Italy) - 9907956
From GDPRhub
| Garante per la protezione dei dati personali - 9907956 | |
|---|---|
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| Authority: | Garante per la protezione dei dati personali (Italy) |
| Jurisdiction: | Italy |
| Relevant Law: | Article 5(1)(a) GDPR Article 5(1)(c) GDPR |
| Type: | Complaint |
| Outcome: | Upheld |
| Started: | 09.07.2021 |
| Decided: | 08.06.2023 |
| Published: | |
| Fine: | 40,660 EUR |
| Parties: | RCS Mediagroup S.p.a. |
| National Case Number/Name: | 9907956 |
| European Case Law Identifier: | n/a |
| Appeal: | Unknown |
| Original Language(s): | Italian |
| Original Source: | Garante (in IT) |
| Initial Contributor: | Bernardo Armentano |
The Italian DPA fined a magazine €40,660 for capturing and publishing images of a public person inside her apartment, in violation of Articles 5(1)(a) and (c) GDPR.
English Summary
Facts
The data subject is a public figure in Italy. In December 2020, when she was in her apartment on the fourth floor of a building, she was photographed kissing a man with whom she was having a relationship at the time. The photo was taken from the street by a journalist and published by the magazine "Oggi" four months after being taken. The data subject contacted the controller, the company RCS Mediagroup S.p.a., responsible for the magazine, requesting that it refrained from further disseminating the images. However, she did not receive a response.
She subsequently filed a complaint with the Italian DPA, claiming that the processing of her personal data was illegal as the photos were taken and published without her knowledge. According to her, these photos portrayed moments of her private life and were published at a time when she was no longer having a relationship with that man. She informed that her apartment is more than 20 meters high and, therefore, she would never have expected that someone would take these photos. In her view, the journalist must have used powerful lenses to be able to capture the images.
In defense, the controller replied that it received the request from the data subject the day before the magazine was distributed and that it could not reveal the author of the shots due to obligations of professional secrecy. The controller claimed that the photographer was inside a car parked on the street and used a zoom of 70 to 200, which does not configure an invasive tool. In addition, it argued added that news about the data subject's romantic relationships are often reported by the media and, therefore, there was a public interest in providing complete information about it. According to the controller, the data subject had several relationships, that she never made a secret of her love life and never protested against the dissemination of articles and images on the subject, which would imply a reiterated consent.
Holding
After investigating the facts, the DPA concluded that the images were captured using invasive techniques as the data subject was in her apartment located on the fourth floor, away from the gaze of passers-by at street level. It noted that she was not easily identifiable by the image itself, but that her identity was disclosed by the controller along with the photos.
The DPA also highlighted that the photos related to moments of the data subject's private life and therefore did not fit the concept of journalistic information of public interest, especially in view of the time lapse between the facts and the publication of the report. In addition, it emphasized that the willingness of the data subject to submit to the "media spotlight" does not legitimize any form of collection and use of data and images concerning her.
Then, the DPA held that the processing of personal data of a strictly private nature was excessive, disproportionate and not justified by the alleged journalistic purpose. Thus, it found the the controller violated the principle of lawfulness and fairness, the principle of data minimization as well as the jornalistic ethical norms regarding the essentiality of information.
For these reasons, it fined the controller €40,660 for the infringement of Articles 5(1)(a) and (c) GDPR.
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English Machine Translation of the Decision
The decision below is a machine translation of the Italian original. Please refer to the Italian original for more details.
SEE ALSO Newsletter of July 26, 2023 [doc. web no. 9907956] Provision of 8 June 2023 Register of measures no. 246 of 8 June 2023 THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA IN today's meeting, which was attended by prof. Pasquale Stanzione, president, prof.ssa Ginevra Cerrina Feroni, vice president, dr. Agostino Ghiglia and the lawyer Guido Scorza, components and the cons. Fabio Mattei, general secretary; HAVING REGARD TO Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter, the "Regulation"); HAVING REGARD TO the Code regarding the protection of personal data, containing provisions for the adaptation of the national legal system to Regulation (EU) 2016/679 (legislative decree 30 June 2003, n. 196, as amended by legislative decree 10 August 2018, n. 101, hereinafter "Code"); HAVING REGARD to the Ethical Rules relating to the processing of personal data in the exercise of journalistic activity" referred to in Annex 1 of the Code (hereinafter "Ethical Rules"); GIVEN the report submitted to the Guarantor, pursuant to art. 144 of the Code, dated 9 July 2021, with which Ms XX, through her lawyer, complained of the violation of legal provisions in relation to the dissemination - in number 18 of the magazine "Oggi", published by RCS Mediagroup S.p.a. (edition of 6 May 2021, distributed on 29 April 2021) - of images that portrayed her while she was inside her home, asking the Guarantor to prohibit their further dissemination; CONSIDERING, in particular, that in the report it was represented that: - the photographs portrayed moments of private life, dating back to December 2020, "taken without the knowledge and, obviously, without the consent of Mrs. XX or of the immortalized subjects", the acquisition and dissemination of which led to a clear violation of the confidentiality of the personal sphere of the whistleblower and her guests; - the home of the interested party is on the fourth floor of a building located in Milan, the windows of which are located at a height of about 20 meters above the ground, a circumstance for which «without the aid of particularly powerful telephoto lenses to overcome the natural distance placed between the person who takes the photograph and the subject of the same, it seems impossible to be aware of what is happening inside the home»; - the published photographs - due to the graininess of the image - highlight the use of a powerful zoom, used from a distance from which a common observer could not have understood what was happening inside the house and therefore allow you to learn what happens inside the house and also to recognize, with reasonable certainty, the identity of the subjects filmed; - the images immortalize a moment of intimacy of the reporting person (the exchange of a kiss shared with an acquaintance); moreover, the advertising launch of April 28, 2021 that preceded the distribution of the magazine (April 29, 2021) did not specify the time when the images were taken, so as to "make readers believe that the images could be contemporary with the disclosure of the news and that , therefore they concealed a sentimental betrayal"; the violation of confidentiality thus materialized was, however, amplified by the diffusion in a newspaper with maximum circulation; - «having acknowledged the existence and successful disclosure of the photographs only on 28.04.2021 on the same date, the reporter sent a warning by e-mail and PEC to the weekly OGGI, as well as to the publisher RCS Mediagroup S.p.a. and ordered them to refrain from further dissemination of the images contesting the occurred violation of privacy"; notice not met by the Publisher, who proceeded with the distribution of the magazine the following day; - the acquisition and disclosure of the photographs constitutes an unlawful processing of personal data in violation of the principles of lawfulness and correctness pursuant to art. 11 [now repealed by Legislative Decree n.101/2018 Editor's note] of the Code, also referred to in art. 5 of the Regulation, and a violation of the art. 3 of the Code of Conduct (now Rules of Conduct, Editor's Note], as well as integrating the criminal case of unlawful interference in private life, pursuant to Article 615 bis of the Criminal Code "having the agents, respectively, unlawfully captured and disclosed images pertaining to the personal sphere of the reporting person" and of his guests "through the use of sophisticated and powerful telephoto lenses capable of overcoming the natural distance between the photographer and the photographed subject" and of capturing images of private life not otherwise freely observable from the outside; this, to no avail highlighted in the article that the windows had not been "shielded by curtains and shutters"; - the legitimacy of the complaints finds support in various recent rulings by the Supreme Court and by the Guarantor himself who was able to express himself in terms of the illegality of the processing with respect to cases completely comparable to the one reported (rulings cited in the application); - in the present case, the exercise of the right to report cannot be invoked in order to consider the consent of the interested party irrelevant, given that "the public interest in the disclosure of images of a well-known subject who exchanges effusions with a one's acquaintance within one's own home cannot in any way prevail, in the balancing act, on the right to privacy of the immortalized subject» with regard to what he does in a place of private residence; in the present case, therefore, the disclosure of the photographs entailed, in addition to damage to the image of the whistleblower, as protected by article 10 of the civil code civ. and by the articles 96 and 97 of the law n.633/1941, also a violation of the art. 8 of the ECHR which establishes respect for personal and family life; GIVEN the note of 28 December 2021 (prot. 64041) with which the Office asked RCS Mediagroup S.p.a. to provide their own observations regarding what is represented in the report; HAVING REGARD to the note of 17 January 2022 (which was followed by some supplementary certified emails of the same date) with which the Company provided a response, objecting: - to have received the reporter's request dated 28 April 2021 (sent to the director in charge) and not to have replied to it because, in addition to deeming it unfounded, it arrived the day before the magazine was distributed; that he then replied to the subsequent request of the whistleblower dated 6 May the following day, representing that he could not give the data of the author of the shots in the name of the provisions that protect professional secrecy; - the groundlessness of the complaints relating to the illicit acquisition of the images, the creation of which took place without the use of any invasive tool, as they were created by the photographer, from inside his car parked on the street «who he used a 70-200 zoom, that is a very normal lens, which can be found in any shop»; therefore not an ultra-invasive telephoto lens or even a "drone", as claimed by the whistleblower, which instead would have produced sharper images than those used «in which the reproduced subjects would not have been autonomously recognizable, without the accompanying commentary »; the portrayed subjects were perfectly visible from the street and therefore reproducible also from the mobile phone, as they were positioned in front of the lighted window not "shielded" by any curtain; - the groundlessness of the complaints relating to the methods of proposing the service, with reference to the time lag between the taking of the photographs and the publication of the news (which, according to the complainant, was not correctly highlighted by the Publisher); on the contrary, the choice of times «is not at all random and further confirms the correctness of the magazine's editor who, having received them at the time of their creation, had not published them, not having received precise data from the photographer on the man's identity, not recognizable from the images in his possession, who was in the company of the reporting person, whose identity, on the other hand, he was certain, having been the photos taken through the unshielded windows of his home»; the publication therefore took place only when the director of the magazine had confirmatory elements of the facts, thanks to the news provided by other information organs, «indicating the date the photos were taken, also for the purpose of highlighting how it was a lasting relationship and still in progress"; - the irrelevance of the interested party's lack of consent to the publication of the photographs, «given their relevance, which made them essential for complete information; and having regard to the frequency with which news and images, concerning affectionate acquaintances of the reporting person, occupy the specialized mass media»; the same, on the other hand, «has never made a secret of her love life, nor has she ever protested the diffusion of articles and images that have dealt with it» and this is also documented by a large and recent press review ( attached to the note from the Company) which "unequivocally illustrates the presence of numerous boyfriends in the life of the fascinating presenter, confirming the fact that the circulation of news and images pertaining to her private life have never been a problem for her, if not - it is not explained why - in the case in question, which allows us to assume an implicit and repeated consent"; HAVING REGARD TO the note dated February 2, 2022 with which the whistleblower replied to the observations of RCS Mediagroup S.p.a. highlighting: - the inadequacy of the arguments regarding the times and contents of the response to the requests of the whistleblower dated 28 April and 6 May; - the absence of evidence regarding the legitimacy of the acquisition of the images, since the photograph provided by RCS Mediagroup S.p.a. is not valid for this purpose. with the note of 17 January 2021 "which demonstrates the complete opposite of what was claimed by the counterparty, i.e. that with an ordinary capture tool, such as a cell phone, it is absolutely impossible to distinguish anything of what happens in the reporting agent's apartment" nor attribute an identity to any individuals present therein; this is demonstrated by the further photographs (attached to the replies of the whistleblower) «taken in logistic and lighting conditions completely similar to those that were present at the time the photographs were taken and then published in the weekly TOGGI» using a latest generation cell phone, (the -Phone 13), who «attest how it is not at all possible, despite the use of the high quality zoom available on the aforementioned mobile phone, to distinguish the features and features of subjects present in Mrs. XX's house since. enlarging the images, even in these conditions, nothing is obtained but an almost indecipherable agglomeration of pixels»; - the speciousness of the statements regarding the timing of the publication, given that the reporter did not claim that there was no indication of the shooting date (December 2020) in the article but that it did not appear at the time of the advertising launch, so as to induce the public - prima facie- to believe that there was a betrayal by the reporting person with respect to the relationship that was actually in progress at the time of publication of the report (April 2021); having waited a few months before publishing the photos, in other words, far from being motivated by the reasons for caution expressed by the Editor, was functional to solicit the curiosity of the public sensitive to this type of news and therefore to a maximum result in magazine sales; - the inconsistency of the reference to other publications portraying the whistleblower, also pertaining to her love life, given that these are images often taken in public places; the extensive press review provided by the Publisher on the other hand confirms that the reporting party "never complained of the presence of photographers and photographs that portrayed her life and also that of her companions" provided they were lawfully stolen; instead, in the present case «the same, for the first time in many years, felt violated in her private sphere and in her confidentiality. unprecedented fact, despite the dozens of publications to which it has been the subject"; a circumstance that does not allow the treatment to be traced back to the exercise of the right to report and to the relative provisions of the Code which allow disregarding the consent of the interested party for the purposes of the treatment itself; HAVING REGARD TO the further exchange of communications between the Office and the lawyer of the reporting entity on 15 and 16 March 2023; GIVEN the note of the Office of 27 March 2023 (prot. n. 51825) with which, pursuant to art. 166, paragraph 5, of the Code, the data controller was notified of the start of the procedure for the possible adoption of the provisions pursuant to art. 58, par. 2, of the Regulation, noting the possible violation of the following provisions: - the general principles of treatment pursuant to art. 5 par.1 of Regulation (EU) 2016/679 and, in particular, the principles referred to in lett. a) and c) (lawfulness, correctness, transparency and minimisation); - Articles 136 et seq. of the Code governing the processing of data for journalistic purposes and other expressions of thought, with particular reference to art. 137, paragraph 3 which prescribes that the dissemination of data takes place in compliance with the parameter of the "essential nature of information regarding facts of public interest"; - the ethical rules referred to in Annex A1 of the Code and in particular the articles 3 and 6; - the art. 2 quater of the Code which establishes that compliance with the ethical rules constitutes an «essential condition for the lawfulness and correctness of the treatment»; - the art. 12 of the Regulation in relation to the duty to respond to the rights exercised pursuant to articles 15-22 of the Regulation and the relative terms to fulfill them; GIVEN the note of 21 April 2023 with which RCS Mediagroup S.p.a., in referring to the defenses expressed in the previous briefs, specified that: - the preventive request formulated by the reporting entity on 28 April 2021 could not be traced back to profiles relating to the processing of your data as it was addressed to the editor of the periodical and aimed at preventing further dissemination of the service and anticipating claims for damages; moreover, it arrived on the day in which the periodical had already been distributed at the newsstands and therefore any reply proved to be useless; - the subsequent request of 6 May 2021, also not attributable to the rights pursuant to articles 15-22 of the Regulation, "was duly verified, by the only person who could respond to the request to know the name of the photographer, which excludes the disputed violation"; - the whistleblower hypothesized the use of telephoto lenses more powerful than those usually mounted on cameras, or even a drone and - to challenge the owner's arguments and support her own - she offered photographs taken not with the instrument that the Company indicated in its memoirs (Canon EOS 5d Mark III with 70-200 mm telephoto lens) but, through the zoom of a mobile phone, "an entirely different and inadequate tool for comparison"; - the supplementary photographic documentation provided by the Company demonstrates the visibility from the street level of «a kiss between the two people present in the room and the woman is unequivocally the appellant, given that this is her home and this even if her features: therefore the passer-by that evening, if he had raised his eyes towards that lighted window, would have had a clear perception of that kiss and, knowing the identity of the owner, would have also understood that it was the appellant herself who was kissing the man who was with her, on 20 December 2020»; - the whistleblower, on the other hand, did not adopt any precautions (curtains) aimed at precluding the visibility from the outside of what was happening in her home, near her window, in the evening, with the light on; - once the legitimacy of the acquisition of the images has been ascertained, their diffusion is to be considered equally lawful: the news was in fact of public interest, "at least for lovers of the subject", given that "the interested party has never concealed flirting and romantic relationships, today also keeping them informed of her pregnancy, with more or less posed photos»; the images were published, not at the time they were taken, but only after the editor of the magazine had learned the man's identity and the couple had disclosed their romantic relationship, thus proving to be "essential to corroborate the dating that relationship» without damaging the image or reputation of the data subject; CONSIDERING that, unless the fact constitutes a more serious offence, whoever, in a proceeding before the Guarantor, falsely declares or certifies news or circumstances or produces false deeds or documents is liable pursuant to art. 168 of the Code "False statements to the Guarantor and interruption of the performance of the duties or exercise of the powers of the Guarantor"; SPECIFYING that the Guarantor is called to assess whether, in the specific case, there has been a processing of personal data that does not comply with the regulations in force on the matter, being unable instead to pronounce on the possible existence of the violation referred to in art. 615 bis code pen. − hypothesis also outlined in the report − this being a profile of competence of the judicial authority; CONSIDERING, in particular, that the publication which is the subject of the complaint must be assessed in the light of the general principles of processing (Article 5 of the Regulation) and of the specific provisions governing journalistic activity, pursuant to Articles 136 - 139 of the Code and of the Deontological Rules pursuant to art. 139 of the Code itself; DETECTED, from the investigative elements that emerged, that the images subject to the report: - have been acquired (and stored) with a remote device; - based on what was stated by the owner himself, the nature of the same - for the view offered by the position of the shot - by themselves did not allow to identify the identity of the subjects taken, which was instead "integrated" into the treatment and revealed by the owner on the occasion of the publication of the journalistic service, which took place four months after the shooting; - portray, unbeknownst to the whistleblower, moments of private life that took place in some rooms of her apartment located at a height (fourth floor) suitable, as such, to suggest a certain reserve with respect to the gaze of those who find themselves passing through the street level; CONSIDERED, due to the characteristics described, that the photographic service reveals an incorrect use of "invasive techniques" (Article 3 of the Deontological Rules) - which can be implemented with more or less common and more or less sophisticated devices - and, therefore, a collection of personal data, even strictly private, in violation of the general principles of correctness and transparency (Article 5, paragraph 1, letter a) of the Regulation) which also operate with reference to processing carried out for journalistic purposes; CONSIDERING on the other hand, that in the present case the conditions for being able to derogate from these principles do not exist due to a possible impossibility of otherwise pursuing the information function (Article 2 of the Code of Conduct), where one also takes into account what has been highlighted by the same owner in his memoirs and that is the circumstance that, very often, it is the whistleblower herself who discloses the facts relating to her private and sentimental life through public behavior or statements; HAVING CONSIDERED in this regard that the willingness shown by the reporting party to submit to the "media spotlight" does not in itself, as claimed by RCS Mediagroup S.p.a., legitimize any form of collection and use of data and images concerning it, having instead on a case-by-case basis, evaluate the existence of the conditions that make the processing lawful (a circumstance already represented to the owner in relation to a similar case: provision 22 December 2009, doc. web no. 1686747, see also for the same case, Cass. civil section I, 16 June 2021, n.17217 and Cass. Civ. section I, 23 January 2019, n. 1875); NOTING that the photographs refer to facts dating back to a few months earlier than the time period in which the journalistic service was released - a circumstance that is not immediately perceptible in the light of how the launch and subsequent packaging of the service itself was carried out - a period in which, moreover , the personal and emotional situation of the complainant - based on what was disclosed by the same through public statements and behavior - did not correspond with the facts proposed in the service being reported; CONSIDERING, in terms of their diffusion, that the purpose declared by the owner − to corroborate the hypothesis of a sentimental relationship between the reporting person and the man portrayed in the photographs (still) in place at the time of publication of the service - as far as can be done fall within a type of journalistic information of public interest (at least with reference to a specific user), cannot justify the compression of the right to respect for the private life of the interested party, even if a public figure, also in the light of the aforementioned time gap between the facts and the publication of the service and therefore of the interference of this editorial choice in the reporting life of the reporter; CONSIDERING that - without prejudice to the foregoing regarding the collection methods - the subsequent use of the images constitutes a processing of personal data, even of a strictly private nature, in excess and such as to determine a disproportionate and not justified with respect to the journalistic purpose pursued (for the benefit of "lovers of the subject", to quote the words of the owner himself), therefore also in contrast with the principles of data minimization (Article 5, paragraph 1, letter c) of the Regulation and "essentiality of the information" pursuant to art. 137, paragraph 3 of the Code and art. 6 of the Deontological Rules; CONSIDERING therefore that the treatment object of the report, in terms of data collection and their dissemination, constitutes a violation of the general principles of lawfulness, correctness and transparency as well as minimization of personal data pursuant to art. 5, par. 1, lit. a) and c) of the Regulation, as subsequently declined - with reference to processing for journalistic purposes - by art. 137, paragraph 3 of the Code and by the Deontological Rules (articles 2, 3 and 6, paragraph 2), the observance of which constitutes an «essential condition for the lawfulness and correctness of the treatment» (article 2 quater of the Code); CONSIDERED therefore, pursuant to articles 57 par. 1, lit. f) of the Regulation, due to the violations found, to have, pursuant to art. 58, par. 2, lit. f), against RCS Mediagroup S.p.a. the prohibition of further dissemination - also online, including the historical archive - except for mere conservation for the purpose of their possible use in court; RECALLING that, in the event of non-compliance with the provisions of the Guarantor contained in this provision, the criminal sanction referred to in art. 170 of the Code, in addition to the administrative sanction pursuant to art. 83, par. 5, letter. e), of the Regulation; CONSIDERING, with regard to the ascertained violation, that it is necessary to adopt an injunction order pursuant to art. 166, paragraph, 7 of the Code and 18 of the law n. 689/1981 for the application of the pecuniary administrative sanction provided for by art. 83, par. 5 of the Regulation; NOTING that, for the determination of the amount of the pecuniary sanction, it is necessary to take into account the elements indicated in art. 83, par. 2 of the Regulation and which, in this case, must be taken into consideration, what aggravating circumstances: a) the seriousness of the violation (Article 83, paragraph 2, of the Regulation), taking into account the method of acquiring personal data and the nature of the data collected, relating to moments of strictly private life which took place in the domicile of the data subject; b) the duration of the violation, given the ongoing availability of the images subject to complaint and the failure to adopt measures aimed at limiting the effects of the processing, together with the partial response to the requests made by the whistleblower when the images were first published; c) the existence of previous violations relating to the provisions relating to journalistic activity, committed by the data controller starting from the entry into force of the Regulation (Article 83, paragraph 2, letter c); d) the relevant organizational, economic and professional conditions of the offender (Article 83, paragraph 2, letter k), of the Regulation) taking into account what emerged in the financial statements for the year 2021; and, as extenuating circumstances: e) the purposes pursued by the owner, attributable - in general terms - to the freedom of information (art. 85) and by the Code (articles 136 et seq.); f) cooperation with the Authority during the preliminary investigation; NOTING that, in application of art. 83, par. 5, of the Regulation, the applicable statutory maximum, based on the Company's turnover resulting from the 2021 financial statements, should be identified in the figure of EUR 20,329,539; CONSIDERING that, based on the combination of factors indicated above and the principles of effectiveness, proportionality and dissuasiveness indicated in art. 83, par. 1 of the Regulation, the administrative sanction of the payment of a sum of Euro 40,660.00 (forty thousand six hundred and sixty/00)), equal to 0.2% of the statutory maximum indicated above, must be applied to the same; HAVING DEEMED that the conditions exist for proceeding with the annotation in the internal register of the Authority pursuant to art. 57, par. 1, lit. u), of the Regulation, in relation to the measures adopted in the specific case in compliance with art. 58, par. 2, of the same Regulation; HAVING REGARD to the documentation in the deeds; GIVEN the observations made pursuant to art. 15 of the Guarantor's regulation n. 1/2000; SPEAKER Prof. Pasquale Stanzione; ALL THIS CONSIDERED pursuant to articles 57 par. 1, lit. f) of the Regulation, declares the report founded for the reasons mentioned in the introduction and, in particular: a) pursuant to art. 58, par. 2, lit. f), orders against RCS Mediagroup S.p.a. the prohibition of further dissemination - also online, including the historical archive - of the photographs of the whistleblower, as in violation of the general principles of lawfulness, correctness and transparency as well as minimization of personal data pursuant to art. 5, par. 1, lit. a) and c) of the Regulation, as subsequently declined - with reference to processing for journalistic purposes - by art. 137, paragraph 3 of the Code and the Deontological Rules (articles 2, 3 and 6, paragraph 2), compliance with which constitutes an «essential condition for the lawfulness and correctness of the processing» (article 2 quater of the Code), without prejudice the mere conservation of the same for the purpose of a possible use in court; b) pursuant to art. 17 of the Guarantor's regulation n. 1/2019, provides for the annotation in the internal register of the Authority pursuant to art. 57, par. 1, lit. u), of the Regulation, of the measures adopted against RCS Mediagroup S.p.a. in compliance with the art. 58, par. 2, of the same Regulation. ORDER pursuant to articles 58, paragraph 2 lett. i) and 83 of the Regulations to RCS Mediagroup S.p.a., with registered office in Milan, via Angelo Rizzoli, 8 – postal code 20132, in the person of its pro-tempore legal representative, to pay the sum of Euro 40,660.00 (forty thousand six hundred and sixty/00), to title of pecuniary administrative sanction for the violations indicated in the motivation, representing that the offender, pursuant to art. 166, paragraph 8, of the Code, has the right to settle the dispute, by paying, within the term of thirty days, an amount equal to half of the fine imposed; ENJOYS to RCS Mediagroup S.p.a., in the event of failure to settle the dispute pursuant to the aforementioned art. 166, paragraph 8, of the Code, to pay the sum of Euro 40,660.00 (forty thousand six hundred and sixty/00), according to the methods indicated in the attachment, within 30 days of notification of this provision, under penalty of the adoption of the consequent executive acts pursuant to the 'art. 27 of the law n. 689/1981. Pursuant to art. 157 of the Code, RCS Mediagroup S.p.a. is invited to communicate, within thirty days from the date of receipt of this provision, what initiatives have been undertaken in order to implement the provisions therein. Please note that failure to respond to the above request is punished with the administrative sanction pursuant to art. 166 of the Code. Pursuant to art. 78 of the Regulation, as well as the articles 152 of the Code and 10 of Legislative Decree lg. 1 September 2011, no. 150, opposition to this provision may be lodged with the ordinary judicial authority, with an appeal filed, alternatively, with the court of the place where the data controller resides or has its registered office or with the court of the place of residence of the interested party within the term of thirty days from the date of communication of the provision itself or sixty days if the appellant resides abroad. Rome, 8 June 2023 PRESIDENT Station THE SPEAKER Station THE SECRETARY GENERAL Matthew SEE ALSO Newsletter of July 26, 2023 [doc. web no. 9907956] Provision of 8 June 2023 Register of measures no. 246 of 8 June 2023 THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA IN today's meeting, which was attended by prof. Pasquale Stanzione, president, prof.ssa Ginevra Cerrina Feroni, vice president, dr. Agostino Ghiglia and the lawyer Guido Scorza, components and the cons. Fabio Mattei, general secretary; HAVING REGARD TO Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter, the "Regulation"); HAVING REGARD TO the Code regarding the protection of personal data, containing provisions for the adaptation of the national legal system to Regulation (EU) 2016/679 (legislative decree 30 June 2003, n. 196, as amended by legislative decree 10 August 2018, n. 101, hereinafter "Code"); HAVING REGARD to the Ethical Rules relating to the processing of personal data in the exercise of journalistic activity" referred to in Annex 1 of the Code (hereinafter "Ethical Rules"); GIVEN the report submitted to the Guarantor, pursuant to art. 144 of the Code, dated 9 July 2021, with which Ms XX, through her lawyer, complained of the violation of legal provisions in relation to the dissemination - in number 18 of the magazine "Oggi", published by RCS Mediagroup S.p.a. (edition of 6 May 2021, distributed on 29 April 2021) - of images that portrayed her while she was inside her home, asking the Guarantor to prohibit their further dissemination; CONSIDERING, in particular, that in the report it was represented that: - the photographs portrayed moments of private life, dating back to December 2020, "taken without the knowledge and, obviously, without the consent of Mrs. XX or of the immortalized subjects", the acquisition and dissemination of which resulted in a clear violation of the confidentiality of the personal sphere of the whistleblower and her guests; - the home of the interested party is on the fourth floor of a building located in Milan, the windows of which are located at a height of about 20 meters above the ground, a circumstance for which «without the aid of particularly powerful telephoto lenses to overcome the natural distance placed between the person who takes the photograph and the subject of the same, it seems impossible to be aware of what is happening inside the home»; - the published photographs - due to the graininess of the image - highlight the use of a powerful zoom, used from a distance from which a common observer could not have understood what was happening inside the house and therefore allow you to learn what happens inside the house and also to recognize, with reasonable certainty, the identity of the subjects filmed; - the images immortalize a moment of intimacy of the reporting person (the exchange of a kiss shared with an acquaintance); moreover, the advertising launch of April 28, 2021 that preceded the distribution of the magazine (April 29, 2021) did not specify the time when the images were taken, so as to "make readers believe that the images could be contemporary with the disclosure of the news and that , therefore they concealed a sentimental betrayal"; the violation of confidentiality thus materialized was, however, amplified by the diffusion in a newspaper with maximum circulation; - «acknowledging the existence and successful disclosure of the photographs only on 28.04.2021 on the same date, the reporter sent warning by e-mail and PEC to the weekly OGGI, as well as to the publisher RCS Mediagroup S.p.a. and ordered them to refrain from further dissemination of the images contesting the occurred violation of privacy"; notice not met by the Publisher, who proceeded with the distribution of the magazine the following day; - the acquisition and disclosure of the photographs constitutes an unlawful processing of personal data in violation of the principles of lawfulness and correctness pursuant to art. 11 [now repealed by Legislative Decree n.101/2018 Editor's note] of the Code, also referred to in art. 5 of the Regulation, and a violation of the art. 3 of the Code of Ethics (now Rules of Ethics, Ed.], in addition to integrating the criminal offense of unlawful interference in private life, pursuant to Article 615 bis of the Italian Criminal Code "having the agents, respectively, unlawfully captured and disclosed images pertaining to the personal sphere of the reporting person" and of his guests "through the use of sophisticated and powerful telephoto lenses capable of overcoming the natural distance between the photographer and the photographed subject" and of capturing images of private life not otherwise freely observable from the outside; this, to no avail highlighted in the article that the windows had not been "shielded by curtains and shutters"; - the legitimacy of the complaints finds support in various recent rulings by the Supreme Court and by the Guarantor himself who was able to express himself in terms of the illegality of the processing with respect to cases completely comparable to the one reported (rulings cited in the application); - in the present case, the exercise of the right to report cannot be invoked in order to consider the consent of the interested party irrelevant, given that "the public interest in the disclosure of images of a well-known subject who exchanges effusions with a one's acquaintance within one's own home cannot in any way prevail, in the balancing act, on the right to privacy of the immortalized subject» with regard to what he does in a place of private residence; in the present case, therefore, the disclosure of the photographs entailed, in addition to damage to the image of the whistleblower, as protected by article 10 of the civil code civ. and by the articles 96 and 97 of the law n.633/1941, also a violation of the art. 8 of the ECHR which establishes respect for personal and family life; GIVEN the note of 28 December 2021 (prot. 64041) with which the Office asked RCS Mediagroup S.p.a. to provide their own observations regarding what is represented in the report; HAVING REGARD to the note of 17 January 2022 (which was followed by some supplementary certified emails of the same date) with which the Company provided a response, objecting: - to have received the reporter's request dated 28 April 2021 (sent to the director in charge) and not to have replied to it because, in addition to deeming it unfounded, it arrived the day before the magazine was distributed; that he then replied to the subsequent request of the whistleblower dated 6 May the following day, representing that he could not give the data of the author of the shots in the name of the provisions that protect professional secrecy; - the groundlessness of the complaints relating to the illicit acquisition of the images, the creation of which took place without the use of any invasive tool, as they were created by the photographer, from inside his car parked on the street «who he used a 70-200 zoom, that is a very normal lens, which can be found in any shop»; therefore not an ultra-invasive telephoto lens or even a "drone", as claimed by the whistleblower, which instead would have produced sharper images than those used «in which the reproduced subjects would not have been autonomously recognizable, without the accompanying commentary »; the portrayed subjects were perfectly visible from the street and therefore reproducible also from the mobile phone, as they were positioned in front of the lighted window not "shielded" by any curtain; - the groundlessness of the complaints relating to the methods of proposing the service, with reference to the time lag between the taking of the photographs and the publication of the news (which, according to the complainant, was not correctly highlighted by the Publisher); on the contrary, the choice of times «is not at all random and further confirms the correctness of the magazine's editor who, having received them at the time of their creation, had not published them, not having received precise data from the photographer on the man's identity, not recognizable from the images in his possession, who was in the company of the reporting person, whose identity, on the other hand, he was certain, having been the photos taken through the unshielded windows of his home"; the publication therefore took place only when the director of the magazine had confirmatory elements of the facts, thanks to the news provided by other information organs, «indicating the date the photos were taken, also for the purpose of highlighting how it was a lasting relationship and still in progress"; - the irrelevance of the interested party's lack of consent to the publication of the photographs, «given their relevance, which made them essential for complete information; and having regard to the frequency with which news and images, concerning affectionate acquaintances of the reporting person, occupy the specialized mass media»; the same, on the other hand, «has never made a secret of her love life, nor has she ever protested the diffusion of articles and images that have dealt with it» and this is also documented by a large and recent press review ( attached to the note from the Company) which "unequivocally illustrates the presence of numerous boyfriends in the life of the fascinating presenter, confirming the fact that the circulation of news and images pertaining to her private life have never been a problem for her, if not - it is not explained why - in the case in question, which allows us to assume an implicit and repeated consent"; HAVING REGARD TO the note dated February 2, 2022 with which the whistleblower replied to the observations of RCS Mediagroup S.p.a. highlighting: - the inadequacy of the arguments regarding the times and contents of the response to the requests of the whistleblower dated 28 April and 6 May; - the absence of evidence regarding the legitimacy of the acquisition of the images, since the photograph provided by RCS Mediagroup S.p.a. is not valid for this purpose. with the note of 17 January 2021 "which demonstrates the complete opposite of what was claimed by the counterparty, i.e. that with an ordinary capture tool, such as a cell phone, it is absolutely impossible to distinguish anything of what happens in the reporting agent's apartment" nor attribute an identity to any individuals present therein; this is demonstrated by the further photographs (attached to the replies of the whistleblower) «taken in logistic and lighting conditions completely similar to those that were present at the time the photographs were taken and then published in the weekly TOGGI» using a latest generation cell phone, (the -Phone 13), who «attest how it is not at all possible, despite the use of the high quality zoom available on the aforementioned mobile phone, to distinguish the features and features of subjects present in Mrs. XX's house since. enlarging the images, even in these conditions, nothing is obtained but an almost indecipherable agglomeration of pixels»; - the speciousness of the statements regarding the timing of the publication, given that the reporter did not claim that there was no indication of the shooting date (December 2020) in the article but that it did not appear at the time of the advertising launch, so as to induce the public - prima facie- to believe that there was a betrayal by the reporting person with respect to the relationship that was actually in progress at the time of publication of the report (April 2021); having waited a few months before publishing the photos, in other words, far from being motivated by the reasons for caution expressed by the Editor, was functional to solicit the curiosity of the public sensitive to this type of news and therefore to a maximum result in magazine sales; - the inconsistency of the reference to other publications portraying the whistleblower, also pertaining to her love life, given that these are images often taken in public places; the extensive press review provided by the Publisher on the other hand confirms that the reporting party "never complained of the presence of photographers and photographs that portrayed her life and also that of her companions" provided they were lawfully stolen; instead, in the present case «the same, for the first time in many years, felt violated in her private sphere and in her confidentiality. unprecedented fact, despite the dozens of publications to which it has been the subject"; a circumstance that does not allow the treatment to be traced back to the exercise of the right to report and to the relative provisions of the Code which allow disregarding the consent of the interested party for the purposes of the treatment itself; HAVING REGARD TO the further exchange of communications between the Office and the lawyer of the reporting entity on 15 and 16 March 2023; GIVEN the note of the Office of 27 March 2023 (prot. n. 51825) with which, pursuant to art. 166, paragraph 5, of the Code, the data controller was notified of the start of the procedure for the possible adoption of the provisions pursuant to art. 58, par. 2, of the Regulation, noting the possible violation of the following provisions: - the general principles of treatment pursuant to art. 5 par.1 of Regulation (EU) 2016/679 and, in particular, the principles referred to in lett. a) and c) (lawfulness, correctness, transparency and minimisation); - Articles 136 et seq. of the Code governing the processing of data for journalistic purposes and other expressions of thought, with particular reference to art. 137, paragraph 3 which prescribes that the dissemination of data takes place in compliance with the parameter of the "essential nature of information regarding facts of public interest"; - the ethical rules referred to in Annex A1 of the Code and in particular the articles 3 and 6; - the art. 2 quater of the Code which establishes that compliance with the ethical rules constitutes an «essential condition for the lawfulness and correctness of the treatment»; - the art. 12 of the Regulation in relation to the duty to respond to the rights exercised pursuant to articles 15-22 of the Regulation and the relative terms to fulfill them; GIVEN the note of 21 April 2023 with which RCS Mediagroup S.p.a., in referring to the defenses expressed in the previous briefs, specified that: - the preventive request formulated by the reporting entity on 28 April 2021 could not be traced back to profiles relating to the processing of your data as it was addressed to the editor of the periodical and aimed at preventing further dissemination of the service and anticipating claims for damages; moreover, it arrived on the day in which the periodical had already been distributed at the newsstands and therefore any reply proved to be useless; - the subsequent request of 6 May 2021, also not attributable to the rights pursuant to articles 15-22 of the Regulation, "was duly verified, by the only person who could respond to the request to know the name of the photographer, which excludes the disputed violation"; - the whistleblower hypothesized the use of telephoto lenses more powerful than those usually mounted on cameras, or even a drone and - to challenge the owner's arguments and support her own - she offered photographs taken not with the instrument that the Company indicated in its memoirs (Canon EOS 5d Mark III with 70-200 mm telephoto lens) but, through the zoom of a mobile phone, "an entirely different and inadequate tool for comparison"; - the supplementary photographic documentation provided by the Company demonstrates the visibility from the street level of «a kiss between the two people present in the room and the woman is unequivocally the appellant, given that this is her home and this even if her features: therefore the passer-by that evening, if he had raised his eyes towards that lighted window, would have had a clear perception of that kiss and, knowing the identity of the owner, would have also understood that it was the appellant herself who was kissing the man who was with her, on 20 December 2020»; - the whistleblower, on the other hand, did not adopt any precautions (curtains) aimed at precluding the visibility from the outside of what was happening in her home, near her window, in the evening, with the light on; - once the legitimacy of the acquisition of the images has been ascertained, their diffusion is to be considered equally lawful: the news was in fact of public interest, "at least for lovers of the subject", given that "the interested party has never concealed flirting and romantic relationships, today also keeping them informed of her pregnancy, with more or less posed photos»; the images were published, not at the time they were taken, but only after the editor of the magazine had learned the man's identity and the couple had disclosed their romantic relationship, thus proving to be "essential to corroborate the dating that relationship» without damaging the image or reputation of the data subject; CONSIDERING that, unless the fact constitutes a more serious offence, whoever, in a proceeding before the Guarantor, falsely declares or certifies news or circumstances or produces false deeds or documents is liable pursuant to art. 168 of the Code "False statements to the Guarantor and interruption of the performance of the duties or exercise of the powers of the Guarantor"; SPECIFYING that the Guarantor is called to assess whether, in the specific case, there has been a processing of personal data that does not comply with the regulations in force on the matter, being unable instead to pronounce on the possible existence of the violation referred to in art. 615 bis code pen. − hypothesis also outlined in the report − this being a profile of competence of the judicial authority; CONSIDERING, in particular, that the publication which is the subject of the complaint must be assessed in the light of the general principles of processing (Article 5 of the Regulation) and of the specific provisions governing journalistic activity, pursuant to Articles 136 - 139 of the Code and of the Deontological Rules pursuant to art. 139 of the Code itself; DETECTED, from the investigative elements that emerged, that the images subject to the report: - have been acquired (and stored) with a remote device; - based on what was stated by the owner himself, the nature of the same - for the view offered by the position of the shot - by themselves did not allow to identify the identity of the subjects taken, which was instead "integrated" into the treatment and revealed by the owner on the occasion of the publication of the journalistic service, which took place four months after the shooting; - portray, unbeknownst to the whistleblower, moments of private life that took place in some rooms of her apartment located at a height (fourth floor) suitable, as such, to suggest a certain reserve with respect to the gaze of those who find themselves passing through the street level; CONSIDERED, due to the characteristics described, that the photographic service reveals an incorrect use of "invasive techniques" (Article 3 of the Deontological Rules) - which can be implemented with more or less common and more or less sophisticated devices - and, therefore, a collection of personal data, even strictly private, in violation of the general principles of correctness and transparency (Article 5, paragraph 1, letter a) of the Regulation) which also operate with reference to processing carried out for journalistic purposes; CONSIDERING on the other hand, that in the present case the conditions for being able to derogate from these principles do not exist due to a possible impossibility of otherwise pursuing the information function (Article 2 of the Code of Conduct), where one also takes into account what has been highlighted by the same owner in his memoirs and that is the circumstance that, very often, it is the whistleblower herself who discloses the facts relating to her private and sentimental life through public behavior or statements; CONSIDERING in this regard that the willingness shown by the whistleblower to submit to the "media spotlight" does not in itself, as claimed by RCS Mediagroup S.p.a., legitimize any form of collection and use of data and images concerning it, since it must instead on a case-by-case basis, evaluate the existence of the conditions that make the processing lawful (a circumstance already represented to the data controller in relation to a similar case: provision of 22 December 2009, web doc. n. 1686747, see also for the same case, Civil Court of Cassation section I, June 16, 2021, no. 17217 and Civil Court of Cassation, section I, January 23, 2019, no. 1875); NOTING that the photographs refer to facts dating back to a few months earlier than the time period in which the journalistic service was released - a circumstance that is not immediately perceptible in the light of how the launch and subsequent packaging of the service itself was carried out - a period in which, moreover , the personal and emotional situation of the complainant - based on what was disclosed by the same through public statements and behavior - did not correspond with the facts proposed in the service being reported; CONSIDERING, in terms of their diffusion, that the purpose declared by the owner − to corroborate the hypothesis of a sentimental relationship between the reporting person and the man portrayed in the photographs (still) in place at the time of publication of the service - as far as can be done fall within a type of journalistic information of public interest (at least with reference to a specific user), cannot justify the compression of the right to respect for the private life of the interested party, even if a public figure, also in the light of the aforementioned time gap between the facts and the publication of the service and therefore of the interference of this editorial choice in the reporting life of the reporter; CONSIDERING that - without prejudice to the foregoing regarding the collection methods - the subsequent use of the images constitutes a processing of personal data, even of a strictly private nature, in excess and such as to determine a disproportionate and not justified with respect to the journalistic purpose pursued (for the benefit of "lovers of the subject", to quote the words of the owner himself), therefore also in contrast with the principles of data minimization (art. 5, par. 1 lit. c) of the Regulation and of "essential information" pursuant to art. 137, paragraph 3 of the Code and art. 6 of the Deontological Rules; CONSIDERING therefore that the treatment object of the report, in terms of data collection and their dissemination, constitutes a violation of the general principles of lawfulness, correctness and transparency as well as minimization of personal data pursuant to art. 5, par. 1, lit. a) and c) of the Regulation, as subsequently declined - with reference to processing for journalistic purposes - by art. 137, paragraph 3 of the Code and by the Deontological Rules (articles 2, 3 and 6, paragraph 2), the observance of which constitutes an «essential condition for the lawfulness and correctness of the treatment» (article 2 quater of the Code); CONSIDERED therefore, pursuant to articles 57 par. 1, lit. f) of the Regulation, due to the violations found, to have, pursuant to art. 58, par. 2, lit. f), against RCS Mediagroup S.p.a. the prohibition of further dissemination - also online, including the historical archive - except for mere conservation for the purpose of their possible use in court; RECALLING that, in the event of non-compliance with the provisions of the Guarantor contained in this provision, the criminal sanction referred to in art. 170 of the Code, in addition to the administrative sanction pursuant to art. 83, par. 5, letter. e), of the Regulation; CONSIDERING, with regard to the ascertained violation, that it is necessary to adopt an injunction order pursuant to art. 166, paragraph, 7 of the Code and 18 of the law n. 689/1981 for the application of the pecuniary administrative sanction provided for by art. 83, par. 5 of the Regulation; NOTING that, for the determination of the amount of the pecuniary sanction, it is necessary to take into account the elements indicated in art. 83, par. 2 of the Regulation and which, in this case, must be taken into consideration, what aggravating circumstances: a) the seriousness of the violation (Article 83, paragraph 2, of the Regulation), taking into account the method of acquiring personal data and the nature of the data collected, relating to moments of strictly private life which took place in the domicile of the data subject; b) the duration of the violation, given the ongoing availability of the images subject to complaint and the failure to adopt measures aimed at limiting the effects of the processing, together with the partial response to the requests made by the whistleblower when the images were first published; c) the existence of previous violations relating to the provisions relating to journalistic activity, committed by the data controller starting from the entry into force of the Regulation (Article 83, paragraph 2, letter c); d) the relevant organizational, economic and professional conditions of the offender (Article 83, paragraph 2, letter k), of the Regulation) taking into account what emerged in the financial statements for the year 2021; and, as extenuating circumstances: e) the purposes pursued by the owner, attributable - in general terms - to the freedom of information (art. 85) and by the Code (articles 136 et seq.); f) cooperation with the Authority during the preliminary investigation; NOTING that, in application of art. 83, par. 5, of the Regulation, the applicable statutory maximum, based on the Company's turnover resulting from the 2021 financial statements, should be identified in the figure of EUR 20,329,539; CONSIDERING that, based on the combination of factors indicated above and the principles of effectiveness, proportionality and dissuasiveness indicated in art. 83, par. 1 of the Regulation, the administrative sanction of the payment of a sum of Euro 40,660.00 (forty thousand six hundred and sixty/00)), equal to 0.2% of the statutory maximum indicated above, must be applied to the same; HAVING DEEMED that the conditions exist for proceeding with the annotation in the internal register of the Authority pursuant to art. 57, par. 1, lit. u), of the Regulation, in relation to the measures adopted in the specific case in compliance with art. 58, par. 2, of the same Regulation; HAVING REGARD to the documentation in the deeds; GIVEN the observations made pursuant to art. 15 of the Guarantor's regulation n. 1/2000; SPEAKER Prof. Pasquale Stanzione; ALL THIS CONSIDERED pursuant to articles 57 par. 1, lit. f) of the Regulation, declares the report founded for the reasons mentioned in the introduction and, in particular: a) pursuant to art. 58, par. 2, lit. f), orders against RCS Mediagroup S.p.a. the prohibition of further dissemination - also online, including the historical archive - of the photographs of the whistleblower, as in violation of the general principles of lawfulness, correctness and transparency as well as minimization of personal data pursuant to art. 5, par. 1, lit. a) and c) of the Regulation, as subsequently declined - with reference to processing for journalistic purposes - by art. 137, paragraph 3 of the Code and the Deontological Rules (articles 2, 3 and 6, paragraph 2), compliance with which constitutes an «essential condition for the lawfulness and correctness of the processing» (article 2 quater of the Code), without prejudice the mere conservation of the same for the purpose of a possible use in court; b) pursuant to art. 17 of the Guarantor's regulation n. 1/2019, provides for the annotation in the internal register of the Authority pursuant to art. 57, par. 1, lit. u), of the Regulation, of the measures adopted against RCS Mediagroup S.p.a. in compliance with the art. 58, par. 2, of the same Regulation. ORDER pursuant to articles 58, paragraph 2 lett. i) and 83 of the Regulations to RCS Mediagroup S.p.a., with registered office in Milan, via Angelo Rizzoli, 8 – postal code 20132, in the person of its pro-tempore legal representative, to pay the sum of Euro 40,660.00 (forty thousand six hundred and sixty/00), to title of pecuniary administrative sanction for the violations indicated in the motivation, representing that the offender, pursuant to art. 166, paragraph 8, of the Code, has the right to settle the dispute, by paying, within the term of thirty days, an amount equal to half of the fine imposed; ENJOYS to RCS Mediagroup S.p.a., in the event of failure to settle the dispute pursuant to the aforementioned art. 166, paragraph 8, of the Code, to pay the sum of Euro 40,660.00 (forty thousand six hundred and sixty/00), according to the methods indicated in the attachment, within 30 days of notification of this provision, under penalty of the adoption of the consequent executive acts pursuant to the 'art. 27 of the law n. 689/1981. Pursuant to art. 157 of the Code, RCS Mediagroup S.p.a. is invited to communicate, within thirty days from the date of receipt of this provision, what initiatives have been undertaken in order to implement the provisions therein. Please note that failure to respond to the above request is punished with the administrative sanction pursuant to art. 166 of the Code. Pursuant to art. 78 of the Regulation, as well as the articles 152 of the Code and 10 of Legislative Decree lg. 1 September 2011, no. 150, opposition to this provision may be lodged with the ordinary judicial authority, with an appeal filed, alternatively, with the court of the place where the data controller resides or has its registered office or with the court of the place of residence of the interested party within the term of thirty days from the date of communication of the provision itself or sixty days if the appellant resides abroad. Rome, 8 June 2023 PRESIDENT Station THE SPEAKER Station THE SECRETARY GENERAL Matthew
