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With the information available, it can be concluded that the jobs of A17 officials who are not LITERate (heads of department) can be considered to be places of special trust, of special responsibility within the organisation or of high pay. Access to individualised information on the pay of public workers must, in principle, be limited to senior managers and staff as well as to staff who hold positions of special trust, of special responsibility within the organisation or high level in the hierarchy of the entity, of free designation, or who carry a high level of pay. With regard to other public workers, the public interest in controlling public activity with regard to the destination of resources could also be satisfied without sacrificing the privacy of the persons concerned in such a way that information must be provided aggregated by groups and levels of intervals. As regards the three-year period of these workers, it would be in line with data protection regulations to provide information grouped by categories or by groups and levels of intervals. It is generally not considered appropriate to data protection regulations to provide information relating to the description, chronologically speaking, of the administrative situation of an entire group of officials throughout their administrative career, whether they are management staff or special responsibility or whether it affects other groups of officials.

Access by the bodies representing public workers to the remuneration information of these people on a case-by-case basis will be conditional upon the applicable legislative provisions and concurrent circumstances in the specific case. University workers' committee members on the negotiating Commission for the Equality Plan must be able to access the information in the Retributive Register, which must comply with the terms of Article 28.2 of the ET, despite having professional categories with a small number of workers, while remaining those obliged to respect the confidentiality of the information obtained, as well as the principle of purpose.

For the information available, in the specific case examined, from the point of view of data protection regulations, there is no problem in giving the councillor access to the dossier of the stabilisation process for municipal workers, provided that it is information strictly necessary to achieve its functions. However, with regard to personal data of special protection (Article 9 of the GDPR) that may be included, it will be necessary to limit access, so that no more data is communicated than is strictly necessary to achieve the legitimate purpose that justifies access, that is, the development of the functions corresponding to councillors. In any case, once the councillor has access to municipal information on the basis of the functions legally mandated, this must be governed by the duty of reservation imposed by the regulations of local regulations, the principle of purpose limitation (Article 5.1.b) GDPR) and the duty of integrity and confidentiality (Article 5.1.f) GDPR.

Data protection regulations do not prevent access to the requested information consisting of the name and surnames of the person who met the head of the Area of Territory of the City Council in the context of a dossier protecting urban planning law, provided that this person has participated as a collegiate technician in the aforementioned dossier. Outside this assumption, access to the requested information should be denied.

The publication of the work census of the Col·legi d'Economistes de Catalunya, which included personal data (name, surnames, sex, DNI, seniority and professional category) of 21 people, relating to the electoral process for choosing the person representing the workers of the CEC, is denounced. It is also reported that the publication was made in a space accessible by people outside the CEC staff. It is archived because the processing has a legal basis and because it has not been proven that the census had been published in a place accessible to third parties.

The complaint is shelved because there is no rational indication of the reported facts. The complainant complained that the City Council would have disclosed its data to third parties, in relation to municipal charges.

Tomando en consideración los términos en que se formula la reclamación la normativa de protección de datos no impide el acceso de la persona reclamante a la información solicitada con la previa pseudonimització de los datos personales.

The access of the councilors to information regarding the amount and reason for the doubtful debts could find its justification in the control and supervision functions legally attributed to the councilors. This, without the need to provide the identity (name and surname) of all affected natural persons, for the purposes of the minimization principle. This, without prejudice to the fact that, once the information is known in the terms indicated, in some cases it may also be pertinent to know the identity of those affected, a possibility that would require specific consideration, taking into account the principles of data protection.

The City Council can keep the minutes of the plenary that are necessary to fulfill the obligations laid down in the transparency law published on the portal. In this case, the minutes of the plenary can be published in the electronic headquarters of the Administer along with the identifying data (name and surname) by reason of the charge, without including, according to the principle of minimization of the data, the publication of the manuscript signature. As for the time it is recommended to keep the full minutes published, this must be temporarily limited to the period necessary to achieve the purpose justifying the publication of the data. As regards the possible application for access to these acts, we should not anonymise the merely identifying data (name, surname) of the ex-registered person who spoke on the occasion of his or her position. As far as handwritten signature is concerned, access would not be justified.

Taking into consideration the terms in which the complaint is made, data protection regulations do not prevent the claimant from accessing the information requested by the prior pseudonymation of personal data.