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The City Council could create a register of the residents of the municipality who, given the concurrence of certain circumstances, would require a quick action by the civil protection forces in emergency situations. The use of data from the Register for this purpose would be compatible, but the incorporation of information relating to people's health would require their explicit consent.

The data protection representative of a town hall requests that the Authority issue an opinion on the legal feasibility and legitimacy of recording images of people at sea for the development of a software and subsequently to implement a system consisting in the real-time capture of images of the beaches (without recording) with the purpose of serving as support in maritime rescue tasks. Current regulations do not give the City Council sufficient authority to implement video surveillance systems that involve the capture of images of identifiable physical persons in the bathing areas of the beaches for the purpose set out in the consultation.

In the consultation it is stated that the CNMT provides the city council with information from the database called the "SGDA" for the management of the Urban Guard emergency care system, in this context the city council raises the possibility of using this database as a means of sending SMS or call notices to its population in emergency and exceptional cases. The principle of limiting the purpose of the GDPR would prevent the city council from using the data from the database of the subscriber data management system (SGDA) provided by the CNMT for a different later purpose, such as warning the population in cases of serious emergencies. The consent of the interested parties collected in a mobile application or website could be a legitimate basis for this treatment.

The registration number of a vehicle has consideration of personal datum in so far as this information can be associated with a physical person and, therefore, make her identifiable without requiring disproportionate efforts. The installation of several cameras in the Catalan road network to pick up this datum with preventive purposes and of management of the risk that it can be derived of the freight transport dangerous it will have to fulfill the forecasts of the Instruction 1/2009. Its treatment only him legitimate considerará when it takes place for the exercise of the functions typical of the administration consulting in the area of its competences, in this case, the exercise of competences on the subject of civil protection.

The data of personal character that figure in the Estate Property Register are given protected by the regulations of protection of particulars, and it is necessary to apply the regime of cessions of the LOPD, taking the forecasts of the Law of the Property Register into account. The company that develops activities destined to the supply of electrical energy, it is titular of a law of real transcendence as the servitude is at the same time regulated in the Law 56/1997 of the electrical sector, for which legitimate access to the data has proteges of the Property Register. With regard to this, the access can be articulated on the part of another company that carries out tasks of maintenance, through an order of the treatment (respecting the forecasts of the article 12 of the LOPD and 20 to 22 of the RLOPD, among others). Of existing municipal competences that required the data processing from the Property Register, beyond the forecasts related to the IBI, the access on the part of the Town Council to these data could, also, remain legitimated.

The particulars contained in the plans of selfprotection and in the general Register of plans of civil protection, find proteges for the LOPD. They consider themselves the accesses to the data for the operating bodies adjusted to the principles of quality and purpose of the LOPD, among others, in so far as these have to intervene in a concrete situation of emergency, which generates the activation of a plan of selfprotection. The communication of data in the town councils where the author companies of plans of selfprotection are found placed, its competences attended to, fits to the forecasts of the article 21 of the LOPD. In relation to other accesses, it would be necessary to appraise the legitimate and direct interest, to the effects of the Law 30/1992. It is necessary to subject equally to the regulations of data protection the accesses and utilization of the particulars treated in the service of management of urgency calls.