Comune di Napoli Corpo di Polizia Municipale: Insufficient legal basis for data processing

The Italian DPA has fined the police authority 'Comune di Napoli Corpo di Polizia Municipale' EUR 12,000. The police authority had sent a list of names, addresses, tax numbers, contact details and appointments for Covid-19 tests of employees to various administrative units via e-mail. The authority referred to the consent given by the employees as the legal basis for the data processing. However, the DPA concluded that the authority could not rely on consent, as voluntary consent is questionable in the employee-employer relationship.

GDPR Articles: Art. 5 (1) a) GDPR, Art. 6 GDPR, Art. 88 GDPR, Art. 113 Codice della privacy
Industry: Public Sector and Education