Garante per la protezione dei dati personali (Italy) - 10138964
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| Garante per la protezione dei dati personali - 10138964 | |
|---|---|
 | |
| Authority: | Garante per la protezione dei dati personali (Italy) |
| Jurisdiction: | Italy |
| Relevant Law: | Article 37(1) GDPR Article 37(7) GDPR |
| Type: | Investigation |
| Outcome: | Violation Found |
| Started: | |
| Decided: | 27.03.2025 |
| Published: | |
| Fine: | 3,000 EUR |
| Parties: | Comune di Palma di Montechiaro |
| National Case Number/Name: | 10138964 |
| European Case Law Identifier: | n/a |
| Appeal: | Unknown |
| Original Language(s): | Italian |
| Original Source: | GPDP (in IT) |
| Initial Contributor: | cci |
Following an ex officio investigation, the DPA fined a municipality €3,000 for failing to appoint a data protection officer.
English Summary
Facts
The municipality of Palma di Montechiaro (the controller) did not communicate the contact details of its DPO to the DPA. The DPA investigated and found that the controller did not appoint a DPO. The controller eventually appointed a DPO after the DPA notified it of the investigation.
Holding
The DPA held that the controller violated Articles 37(1) and (7) by failing to appoint a DPO and to communicate their contact details to the DPA. The DPA issued a €3,000 fine.
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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.
[web doc. no. 10138964] Provision of 27 March 2025 Register of provisions no. 166 of 27 March 2025 THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA IN today's meeting, attended by Prof. Pasquale Stanzione, President, Prof. Ginevra Cerrina Feroni, Vice President, Dr. Agostino Ghiglia and Attorney Guido Scorza, members, and Councillor Fabio Mattei, Secretary General; HAVING SEEN Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, “General Data Protection Regulation” (hereinafter, Regulation); HAVING SEEN Legislative Decree no. 196 of 30 June 2003, containing the Personal Data Protection Code (hereinafter, the Code); HAVING SEEN Regulation no. 1/2019 concerning internal procedures with external relevance, aimed at carrying out the tasks and exercising the powers assigned to the Guarantor for the protection of personal data, approved with resolution no. 98 of 4 April 2019, published in the Official Journal no. 106 of 8 May 2019 and in www.gpdp.it, web doc. no. 9107633 (hereinafter, Guarantor Regulation no. 1/2019); HAVING SEEN the documentation in the files; HAVING SEEN the observations formulated by the Secretary General pursuant to art. 15 of the Guarantor Regulation no. 1/2000 on the organization and functioning of the office of the Guarantor for the protection of personal data, web doc. no. 1098801; Rapporteur Dr. Agostino Ghiglia; WHEREAS 1. Introduction As part of a series of checks carried out ex officio by this Authority, a check carried out on XX does not show that the Municipality of Palma di Montechiaro (hereinafter, Municipality) has communicated the contact details of the Data Protection Officer (hereinafter, DPO) to the Authority - using the dedicated channel available on the page https://servizi.gpdp.it/comunicazionerpd/s/ - required by art. 37, par. 7, of the Regulation. Furthermore, from a contextual check carried out on the institutional website of the Municipality, it was not possible to find the contact details of the DPO, therefore not finding elements capable of proving the designation, by the Municipality, of the DPO. Therefore, with note of XX (prot. no. XX), the Office, on the basis of the elements acquired and the checks carried out, notified the Municipality, pursuant to art. 166, paragraph 5, of the Code, of the initiation of the procedure for the adoption of the provisions referred to in art. 58, paragraph 2, of the Regulation, as it had neither published nor communicated to the Authority the contact details of the DPO, in violation of art. 37, paragraph 7, of the Regulation, and as, on the basis of this, it was not proven that the Municipality had actually designated the DPO, in violation of art. 37, paragraph 1, of the Regulation. With the same note, the aforementioned owner was invited to produce defensive documents or documents to the Guarantor or to request to be heard by the Authority (art. 166, paragraphs 6 and 7, of the Code, as well as art. 18, paragraph 1, of Law 24 November 1981, no. 689). With notes sent on XX (prot. no. XX) and XX (prot. no. XX), the Municipality, in addition to specifying that it did not request a hearing, presented its defensive documents, where it represented, in particular, that: - “With determination of the Secretary General No. XX of XX, this body has designated the […] Data Protection Officer (DPO) of the Municipality of Palma di Montechiaro”; - “On XX, the contact details of the Data Protection Officer (DPO) were communicated via online procedure”. Furthermore, following further discussions, it emerged that the Municipality subsequently published the contact details of the DPO, on its institutional website, on the web page “Responsabile della protezione dei dati personali (Rdp) - Data protection officer (Dpo)”, made available on https://www.comune.palmadimontechiaro.ag.it/flex/cm/pages/ServeBLOB.php/L/IT/IDPagina/10441 ) and also accessible from the homepage of the same website under the heading “DPO” at the bottom. 2. Outcome of the investigation activity Pursuant to art. 37 of the Regulation, the data controller (and the data processor) “[shall] systematically designate a data protection officer whenever: (a) processing is carried out by a public authority or body, except for courts acting in their judicial capacity” (par. 1, letter a)) and “shall publish the contact details of the data protection officer and communicate them to the supervisory authority” (par. 7). Furthermore, the Guidelines on Data Protection Officers (DPOs), adopted by the Article 29 Working Party on Personal Data Protection on 13 December 2016 and amended on 5 April 2017, add that “There is no definition of “public authority” or “public body” in the Regulation. The WP29 considers that such a definition should be in accordance with national law; accordingly, public authorities or public bodies are national, regional and local authorities, but, depending on the applicable national law, the notion also covers a whole range of other public law bodies.12 In these cases, the appointment of a DPO is mandatory” (para. 2.1.1), and that “Article 37, seventh paragraph, of the GDPR requires the controller or processor to publish the contact details of the DPO, and to communicate the contact details of the DPO to the relevant supervisory authorities. These provisions aim to ensure that both data subjects (inside or outside the controller or processor) and the data subjects are informed of the DPO’s contact details. the supervisory authorities can contact the DPO easily and directly without having to contact another structure operating at the owner/manager” (par. 2.6). Also the Guideline Document on the designation, position and tasks of the Data Protection Officer (DPO) in the public sector, adopted by the Guarantor on 29 April 2021 with provision no. 186 (web doc. no. 9589104), specifies that “there is an obligation to designate all public entities, pursuant to letter a) of art. 37, par. 1, of the Regulation, such as, for example: State administrations, including those with autonomous organization, including schools; national, regional and local non-economic public bodies; Regions and local authorities; Universities; Chambers of Commerce, Industry, Crafts and Agriculture; National Health Service Companies; Independent Authorities (see, for purely indicative and non-exhaustive purposes, the list referred to in art. 1, paragraph 2, of Legislative Decree no. 165 of 30 March 2001)” (par. 3), that “With regard to publication, this must be carried out on the administration’s website, within a section that is easily recognizable by the user and accessible from the homepage, as well as within the dedicated section to the organization chart of the entity and its contacts”, and that “With regard to communication to the Authority, it should be noted that the Guarantor has made available a specific online procedure not only for communication, but also for the change and revocation of the name of the designated DPO. This procedure represents the only contact channel that can be used for this specific purpose and can be found on the page https://servizi.gpdp.it/comunicazionerpd/s/, where the specific instructions and the related FAQs are also reported: moreover, the attention of the entities is drawn to correctly enter the requested data, such as the identification of the data controller (the entity as a whole, and not the legal representative) and the compilation of the administration’s tax code (and not the VAT number, or the tax code of another entity)” (paragraph 7). That said, it should be noted that the declarations made by the Municipality during the investigation – for the truthfulness of which one can be held accountable pursuant to art. 168 of the Code – although worthy of consideration, do not allow to overcome the findings notified by the Office with the act of initiation of the procedure and are insufficient to allow the archiving of the present procedure, since, moreover, none of the cases provided for by art. 11 of the regulation of the Guarantor no. 1/2019 apply. This, since the designation of the DPO and, consequently, the related obligations of publication and communication of the relative contact details, were implemented by the Municipality only in XX, following the initiation of the procedure by the Authority. Therefore, the preliminary assessments of the Office are confirmed and the violation of art. 37, paragraphs 1 and 7, of the Regulation is noted, since the Municipality, up to XX, had not designated the DPO and, consequently, had not published or communicated to the Authority the relative contact details. However, since the Municipality subsequently carried out the aforementioned obligations, the conditions for the adoption of the specific corrective measures referred to in art. 58, par. 2, letter d), of the Regulation do not exist. 3. Adoption of the injunction order for the application of the administrative pecuniary sanction (art. 58, par. 2, letter i), and art. 83 of the Regulation; art. 166, paragraph 7, of the Code) The Guarantor, pursuant to art. 58, par. 2, letter i), and art. 83 of the Regulation, as well as art. 166 of the Code, has the power to “impose an administrative pecuniary sanction pursuant to Article 83, in addition to the [other] [corrective] measures referred to in this paragraph, or in place of such measures, depending on the circumstances of each individual case” and, in this context, “the [Guarantor] Board adopts the injunction order, with which it also provides for the application of the accessory administrative sanction to be published, in full or in extract, on the Guarantor's website pursuant to Article 166, paragraph 7, of the Code” (Article 16, paragraph 1, of the Guarantor's regulation no. 1/2019). In this regard, in this case, the violation of the provisions cited is subject to the application of the administrative pecuniary sanction provided for by art. 83, par. 4, of the Regulation. The aforementioned administrative pecuniary sanction, imposed according to the circumstances of each individual case, must be determined in amount taking into due account the elements provided for by art. 83, par. 2, of the Regulation, in relation to which the following is observed. The failure to designate the DPO, up to XX, deprived the Consortium of a mandatory and essential figure to ensure compliance with the Regulation. On the other hand, it is observed that the Municipality has taken action in order to remedy the violations and that it is not charged with previous relevant violations committed or previous measures referred to in art. 58 of the Regulation. On the basis of the above elements, assessed as a whole, it is deemed appropriate to determine the amount of the pecuniary sanction in the amount of Euro 3,000 (three thousand) for the violation of art. 37, paragraphs 1 and 7, of the Regulation as an administrative pecuniary sanction deemed, pursuant to art. 83, paragraph 1, of the Regulation, to be effective, proportionate and dissuasive. It is also believed that the accessory sanction of the publication of this provision on the website of the Guarantor, provided for by art. 166, paragraph 7, of the Code and by art. 16 of the Guarantor regulation no. 1/2019, should be applied, since this concerns the failure to fulfill, up to XX, an obligation that has become mandatory since 2018. Finally, it is believed that the conditions set out in art. 17 of the Guarantor regulation no. 1/2019 are met. NOW, CONSIDERING ALL THE ABOVE, THE GUARANTOR pursuant to art. 57, par. 1, letter a), of the Regulation, declares the conduct of the Municipality of Palma di Montechiaro, described in the terms of the reasons, to be unlawful, consisting in the violation of art. 37, par. 1 and 7, of the Regulation; ORDERS the Municipality of Palma di Montechiaro, with registered office in via Fiorentino 89, 92020, Palma di Montechiaro (AG) – CF 81000070847, pursuant to art. 58, par. 2, letter i), and art. 83 of the Regulation, to pay the sum of Euro 3,000 (three thousand) as an administrative pecuniary sanction for the violations indicated in the reasons; ORDER The Municipality of Palma di Montechiaro to pay the sum of Euro 3,000 (three thousand), 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 actions pursuant to art. 27 of Law 689/1981. In this regard, it is recalled that the right of the offender to settle the dispute by paying, always according to the methods indicated in the attachment, an amount equal to half of the fine imposed, within 30 days of the date of notification of this provision, pursuant to art. 166, paragraph 8, of the Code (see also art. 10, paragraph 3, of Legislative Decree no. 150 of 1 September 2011) remains intact; ORDERS - pursuant to art. 166, paragraph 7, of the Code and art. 16, paragraph 1, of the regulation of the Guarantor no. 1/2019, the publication of the injunction order on the website of the Guarantor; - pursuant to art. 154-bis, paragraph 3, of the Code and art. 37 of the regulation of the Guarantor no. 1/2019, the publication of this provision on the website of the Guarantor; - pursuant to art. 17 of the regulation of the Guarantor no. 1/2019, the annotation of the violations and measures adopted in accordance with art. 58, paragraph 2 of the Regulation, in the internal register of the Authority provided for by art. 57, paragraph 1, letter u) of the Regulation. Pursuant to art. 78 of the Regulation, art. 152 of the Code and art. 10 of Legislative Decree 150/2011, an appeal against this provision may be lodged before the ordinary judicial authority, under penalty of inadmissibility, within thirty days of the date of communication of the provision itself or within sixty days if the appellant resides abroad. Rome, 27 March 2025 THE PRESIDENT Stanzione THE REPORTER Ghiglia THE GENERAL SECRETARY Mattei [web doc. no. 10138964] Provision of 27 March 2025 Register of provisions no. 166 of 27 March 2025 THE GUARANTOR FOR THE PROTECTION OF PERSONAL DATA IN TODAY'S meeting, attended by Prof. Pasquale Stanzione, President, Prof. Ginevra Cerrina Feroni, Vice President, Dr. Agostino Ghiglia and the lawyer Guido Scorza, members, and the councilor Fabio Mattei, general secretary; HAVING SEEN Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC, “General Data Protection Regulation” (hereinafter, the Regulation); HAVING SEEN Legislative Decree no. 196 of 30 June 2003, containing the Personal Data Protection Code (hereinafter, the Code); HAVING SEEN Regulation no. 1/2019 concerning internal procedures with external relevance, aimed at carrying out the tasks and exercising the powers delegated to the Guarantor for the protection of personal data, approved with resolution no. 98 of 4 April 2019, published in the Official Journal no. 106 of 8 May 2019 and in www.gpdp.it, web doc. no. 9107633 (hereinafter, Regulation of the Guarantor no. 1/2019); SEEN the documentation in the files; SEEN the observations formulated by the Secretary General pursuant to art. 15 of the Regulation of the Guarantor no. 1/2000 on the organization and functioning of the office of the Guarantor for the protection of personal data, web doc. no. 1098801; Rapporteur Dr. Agostino Ghiglia; WHEREAS 1. Introduction As part of a series of checks carried out ex officio by this Authority, a check carried out on XX does not show that the Municipality of Palma di Montechiaro (hereinafter, the Municipality) has communicated the contact details of the Data Protection Officer (hereinafter, the DPO) to the Authority – using the dedicated channel available on the page https://servizi.gpdp.it/comunicazionerpd/s/ – as required by art. 37, par. 7, of the Regulation. Furthermore, from a contextual check carried out on the institutional website of the Municipality, it was not possible to find the contact details of the DPO, therefore not finding elements capable of proving the designation, by the Municipality, of the DPO. Therefore, with a note of XX (prot. no. XX), the Office, on the basis of the elements acquired and the checks carried out, notified the Municipality, pursuant to art. 166, paragraph 5, of the Code, the initiation of the procedure for the adoption of the provisions referred to in art. 58, paragraph 2, of the Regulation, as it had not published or communicated to the Authority the contact details of the DPO, in violation of art. 37, paragraph 7, of the Regulation, and as, on the basis of this, it was not proven that the Municipality had actually designated the DPO, in violation of art. 37, paragraph 1, of the Regulation. With the same note, the aforementioned owner was invited to produce defensive writings or documents to the Guarantor or to request to be heard by the Authority (art. 166, paragraphs 6 and 7, of the Code, as well as art. 18, paragraph 1, of Law 24 November 1981, no. 689). With notes sent on XX (prot. no. XX) and XX (prot. no. XX), the Municipality, in addition to specifying that it did not request a hearing, presented its defense papers, where it represented, in particular, that: - “With determination of the Secretary General No. XX of XX, this body has designated the […] Data Protection Officer (DPO) of the Municipality of Palma di Montechiaro”; - “On XX, the contact details of the Data Protection Officer (DPO) were communicated via online procedure”. Furthermore, following further discussions, it emerged that the Municipality subsequently published the contact details of the DPO, on its institutional website, on the web page “Responsabile della protezione dei dati personali (Rdp) - Data protection officer (Dpo)”, made available on https://www.comune.palmadimontechiaro.ag.it/flex/cm/pages/ServeBLOB.php/L/IT/IDPagina/10441 ) and also accessible from the homepage of the same website under the heading “DPO” at the bottom. 2. Outcome of the investigation activity Pursuant to art. 37 of the Regulation, the data controller (and the data processor) “[shall] systematically designate a data protection officer whenever: (a) processing is carried out by a public authority or body, except for courts acting in their judicial capacity” (par. 1, letter a)) and “shall publish the contact details of the data protection officer and communicate them to the supervisory authority” (par. 7). Furthermore, the Guidelines on Data Protection Officers (DPOs), adopted by the Article 29 Working Party on Personal Data Protection on 13 December 2016 and amended on 5 April 2017, add that “There is no definition of “public authority” or “public body” in the Regulation. The WP29 considers that such a definition should be in accordance with national law; accordingly, public authorities or public bodies are national, regional and local authorities, but, depending on the applicable national law, the notion also covers a whole range of other public law bodies.12 In these cases, the appointment of a DPO is mandatory” (para. 2.1.1), and that “Article 37, seventh paragraph, of the GDPR requires the controller or processor to publish the contact details of the DPO, and to communicate the contact details of the DPO to the relevant supervisory authorities. These provisions aim to ensure that both data subjects (inside or outside the controller or processor) and the data subjects are informed of the DPO’s contact details. the supervisory authorities can contact the DPO easily and directly without having to contact another structure operating at the controller/processor” (par. 2.6). The Guideline Document on the designation, position and duties of the Data Protection Officer (DPO) in the public sector, adopted by the Guarantor on 29 April 2021 with provision no. 186 (web doc. no. 9589104), specifies that “there is an obligation to designate all public entities, pursuant to letter a) of art. 37, par. 1, of the Regulation, such as, for example: State administrations, including those with autonomous organization, including schools; national, regional and local non-economic public bodies; Regions and local authorities; Universities; Chambers of Commerce, Industry, Crafts and Agriculture; National Health Service Companies; Independent Authorities (see, for purely indicative and non-exhaustive purposes, the list referred to in art. 1, paragraph 2, of Legislative Decree no. 165 of 30 March 2001)” (par. 3), that “With regard to publication, this must be carried out on the administration’s website, within a section that is easily recognizable by the user and accessible from the homepage, as well as within the dedicated section to the organization chart of the entity and its contacts”, and that “With regard to communication to the Authority, it should be noted that the Guarantor has made available a specific online procedure not only for communication, but also for the change and revocation of the name of the designated DPO. This procedure represents the only contact channel that can be used for this specific purpose and can be found on the page https://servizi.gpdp.it/comunicazionerpd/s/, where the specific instructions and the related FAQs are also reported: moreover, the attention of the entities is drawn to correctly enter the requested data, such as the identification of the data controller (the entity as a whole, and not the legal representative) and the compilation of the administration’s tax code (and not the VAT number, or the tax code of another entity)” (paragraph 7). That said, it should be noted that the declarations made by the Municipality during the investigation – for the truthfulness of which one can be held accountable pursuant to art. 168 of the Code – although worthy of consideration, do not allow to overcome the findings notified by the Office with the act of initiation of the procedure and are insufficient to allow the archiving of the present procedure, since, moreover, none of the cases provided for by art. 11 of the regulation of the Guarantor no. 1/2019 apply. This, since the designation of the DPO and, consequently, the related obligations of publication and communication of the relative contact details, were implemented by the Municipality only in XX, following the initiation of the procedure by the Authority. Therefore, the preliminary assessments of the Office are confirmed and the violation of art. 37, paragraphs 1 and 7, of the Regulation is noted, since the Municipality, up to XX, had not designated the DPO and, consequently, had not published or communicated to the Authority the relative contact details. However, since the Municipality subsequently carried out the aforementioned obligations, the conditions for the adoption of the specific corrective measures referred to in art. 58, par. 2, letter d), of the Regulation do not exist. 3. Adoption of the injunction order for the application of the administrative pecuniary sanction (art. 58, par. 2, letter i), and art. 83 of the Regulation; art. 166, paragraph 7, of the Code) The Guarantor, pursuant to art. 58, par. 2, letter i), and art. 83 of the Regulation, as well as art. 166 of the Code, has the power to “impose a pecuniary administrative sanction pursuant to Article 83, in addition to the [other] [corrective] measures referred to in this paragraph, or in place of such measures, depending on the circumstances of each individual case” and, in this context, “the [Garante] Board adopts the injunction order, with which it also provides for the application of the accessory administrative sanction of its publication, in full or in extract, on the website of the Garante pursuant to Article 166, paragraph 7, of the Code” (Article 16, paragraph 1, of the Garante Regulation no. 1/2019). In this regard, in this case, the violation of the provisions cited is subject to the application of the pecuniary administrative sanction provided for by Article 83, paragraph 4, of the Regulation. The aforementioned administrative fine, imposed according to the circumstances of each individual case, must be determined in amount taking into due account the elements provided for by art. 83, par. 2, of the Regulation, in relation to which the following is noted. The failure to designate the DPO, up to XX, has deprived the Consortium of a mandatory and essential figure to ensure compliance with the Regulation. On the other hand, it is noted that the Municipality has taken action to remedy the violations and that it is not responsible for any previous relevant violations committed or previous measures referred to in art. 58 of the Regulation. In light of the aforementioned elements, assessed as a whole, it is deemed appropriate to determine the amount of the fine in the amount of Euro 3,000 (three thousand) for the violation of art. 37, par. 1 and 7, of the Regulation as an administrative fine deemed, pursuant to art. 83, par. 1, of the Regulation, effective, proportionate and dissuasive. It is also believed that the accessory sanction of publication on the website of the Guarantor of this provision should be applied, provided for by art. 166, paragraph 7, of the Code and by art. 16 of the Guarantor regulation no. 1/2019, since it concerns the failure to fulfill, up to the XX, an obligation that has become mandatory since 2018. Finally, it is believed that the conditions set out in art. 17 of the Guarantor regulation no. 1/2019 exist. GIVEN ALL THE ABOVE, THE GUARANTOR pursuant to art. 57, paragraph 1, letter a), of the Regulation, declares the conduct held by the Municipality of Palma di Montechiaro, described in the terms set out in the motivation, to be unlawful, consisting in the violation of art. 37, paragraphs 1 and 7, of the Regulation; ORDERS the Municipality of Palma di Montechiaro, with registered office in via Fiorentino 89, 92020, Palma di Montechiaro (AG) – CF 81000070847, pursuant to art. 58, par. 2, letter i), and art. 83 of the Regulation, to pay the sum of 3,000 (three thousand) euros as an administrative fine for the violations indicated in the reasons; ORDERS the Municipality of Palma di Montechiaro to pay the sum of 3,000 (three thousand) euros, according to the methods indicated in the attachment, within 30 days of notification of this provision, under penalty of adopting the consequent executive acts pursuant to art. 27 of Law 689/1981. In this regard, it is recalled that the right of the offender to settle the dispute by paying, always according to the methods indicated in the attachment, an amount equal to half of the fine imposed, within 30 days from the date of notification of this provision, pursuant to art. 166, paragraph 8, of the Code (see also art. 10, paragraph 3, of Legislative Decree no. 150 of 1 September 2011); ORDERS - pursuant to art. 166, paragraph 7, of the Code and art. 16, paragraph 1, of the Guarantor regulation no. 1/2019, the publication of the injunction order on the Guarantor's website; - pursuant to art. 154-bis, paragraph 3, of the Code and art. 37 of the Guarantor regulation no. 1/2019, the publication of this provision on the website of the Guarantor; - pursuant to art. 17 of the Guarantor regulation no. 1/2019, the annotation of the violations and measures adopted in accordance with art. 58, par. 2 of the Regulation, in the internal register of the Authority provided for by art. 57, par. 1, letter u) of the Regulation. Pursuant to art. 78 of the Regulation, art. 152 of the Code and art. 10 of Legislative Decree 150/2011, an appeal against this provision may be lodged before the ordinary judicial authority, under penalty of inadmissibility, within thirty days from the date of communication of the provision itself or within sixty days if the appellant resides abroad. Rome, 27 March 2025 THE PRESIDENT Stanzione THE REPORTER Ghiglia THE SECRETARY GENERAL Mattei
