Communication of data among the lender companies of the service of water supply and the municipal social services

In accordance with the valid regulations in the moment of issuing this judgement, the supplying companies can communicate to the social services, without consent of the affected persons, the data identificatives and of contact necessary (name and surnames of the headline of the service, its NIF/NIE and the address of the subminstrament -physical address-, telephone or electronic mail address, and number of supply contract), to be able to contact these, in a previous way to a cut of supply being produced, in order to elaborate the pertinent report (art. 6.4 Law 24/2015). In these cases the social services can also inform in the company about if it coincides or not the foreseen supposition (art. 5.10 Law 24/2015). There is not sufficient legal habilitation to communicate the social services data, on the part of the supplying companies, related to cases of impagaments in a way general and preventive, and in relation to an indeterminate number of persons. The affected persons have to be able to exercise the law of opposition (art. 6.4 LOPD and 21 RGPD).