# Comune di Borgia: Insufficient legal basis for data processing

- Type: Enforcement
- Source: Italian Data Protection Authority (Garante)
- Date: 2022-12-15
- Original: https://www.enforcementtracker.com/ETid-1634
- Canonical: https://overview.legal/posts/47749
- Topics: Special Categories of Data, Biometric Data, Types of Special Categories of Personal Data, Biometric Data, Employees, Personal Data, IP Address, Processing, Public Authority, Processing Agreement

## Summary

The Italian DPA (Garante) imposed a fine of EUR 5,000 on Comune di Borgia. The municipality processed biometric data of employees for the purpose of registering their attendance. Garante found that such processing was not proportionate and therefore constituted an unjustified infringement of the rights of the data subjects. Subsequently, Garante determined that the processing of biometric data had taken place without a legal basis. Also the Garante found that the municipality failed to provide t

## Full text

The Italian DPA (Garante) imposed a fine of EUR 5,000 on Comune di Borgia. The municipality processed biometric data of employees for the purpose of registering their attendance. Garante found that such processing was not proportionate and therefore constituted an unjustified infringement of the rights of the data subjects. Subsequently, Garante determined that the processing of biometric data had taken place without a legal basis. Also the Garante found that the municipality failed to provide the DPA the contact data of their data protections officer.

GDPR Articles: Art. 5 (1) a) GDPR, Art. 6 GDPR, Art. 9 (2), (4) GDPR, Art. 37 (7) GDPR
Industry: Employment

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