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

- Type: Enforcement
- Source: Italian Data Protection Authority (Garante)
- Date: 2022-07-21
- Original: https://www.enforcementtracker.com/ETid-1463
- Canonical: https://overview.legal/posts/47578
- Topics: Processors, Controllers, Processing Agreement, IP Address, Processing, Data Processor, Supervisory Authorities, Law Enforcement

## Summary

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

## Full text

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.

GDPR Articles: Art. 5 (1) a) GDPR, Art. 6 GDPR, Art. 30 (2) GDPR, Art. 2-ter Codice della privacy
Industry: Industry and Commerce

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