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Enforcement · Italian Data Protection Authority (Garante) EN LLM context A cited markdown file you can paste into your AI assistant (ChatGPT, Claude, a RAG or project knowledge base) to ground it in this document. Contains: this document’s text, its sections with their topics, and the full text of every law provision it applies. Everything links back to its source on overview.legal — legal information, not advice.

Clio S.r.l.: Insufficient legal basis for data processing

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The Italian DPA has imposed a fine of EUR 10,000 on Clio S.r.l.. Clio provides and manages a whistleblowing reporting application for various private and public entities. As part of its investigation, the DPA found that Clio had not adequately regulated its relationship with customers. In addition, Clio provided data on whistleblowing reports to customers without a valid legal basis. The DPA considered this to be a violation of Art. 5 (1) a) GDPR and Art. 6 GDPR. Further, the DPA found that Clio had failed to maintain a register of activity carried out in its role as a processor. The DPA considered this to be a violation of Art. 30 (2) GDPR.

Industry: Industry and Commerce

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