Cession in the Town Council, during the kidnapping of the concession, of particulars of the subscribers to the public service

In the examined case, the dealer company of the public service of management of the sport facilities, since it decides, the contents and the use of the treatment of the particulars of the subscribers to the service, about the purpose it has consideration of responsible for the treatment. The fact that the Town Council carries out the temporary kidnapping of this service in principle does not seem that it has to entail necessarily the cession of the data of the subscribers on the part of the dealer company. Otherwise, the communication of these data in the Town Council, without consent, could find habilitation in the article 11.2.c) of the LOPD, in attention to the authorities that the regulations of local regime attribute to the titular administration of the service (the Town Council).