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The hospital could communicate pseudonymized data relating to the health of patients treated with medicines for compassionate use in the pharmaceutical laboratory that facilitates the drug for clinical research purposes (Article 9.2.j) GDPR and paragraph 2.d) of DA 17a LOPDGDD) on the basis of the legitimate interest pursued by the laboratory.

Given the regulatory provisions (art. 6.1.a), art. 9.2.a) RGPD, in connection with Additional Provision 17a of the LOPDGDD) the explicit consent of the data subjects could enable the processing of data. The study may also be carried out with pseudonymous data, in accordance with subparagraph (d) of the said Additional Provision 17a. In any case, the principles and guarantees established in the data protection regulations, the aforementioned additional provision 17 and, where applicable, the Biomedical Research Act must be complied with. The communication of anonymous and aggregated information on the results of the operation carried out by the Foundation to the business fabric of the region would not be contrary to data protection regulations.

Choosing the most appropriate selective collection model in the municipality requires an impact assessment on data protection. The City Council, in view of the powers it has been assigned in matters of waste management, would be entitled to carry out the processing of data arising from the implementation of the selective collection system. However, in the absence of a specific legal provision, the development of profiles that produce legal effects on the person using the service or that significantly affect them in a similar way, requires the explicit consent of the persons affected. The participation of third parties in the implementation of this system requires the formalization of a contract of manager and, where applicable, of sub-manager, as well as, where applicable, the fulfillment of the obligations established in this regard in the LCSP.

The telephone number and e-mail address, as long as it can be directly or indirectly associated with an individual, are personal data whose processing must comply with the principles and guarantees of data protection regulations. The publication of data relating to the name of the establishment, the industrial address of the establishment, telephone number, e-mail address, website, direct link to the location on the map and geographical location coordinates of the companies registered in the RIAAC, may based on the consent of those affected. The dissemination of this data may also be based on the provisions of Articles 19.3 LOPDGDD and 6.4 RGPD, provided that the persons concerned are offered the possibility of requesting the exclusion of their company from the dissemination.

In order to minimize the risks to the security of civil servants who are victims of gender-based violence in the various publications of the general competitions for merit and capacity in which they participate and until the protocol referred to in section 2 of the DA7a of the LOPDGDD, pseudonymous data could be used both for the identification of the contestants who hold such a condition, and for the identification of the place awarded to each of the contestants.

The City Council wants to access the workers of a concessionary company for the municipal gardening service, road cleaning and waste collection, in order to study the economic data for the purpose of assessing a possible subrogation of the service. To this end, check whether certain data of the workers are personal data and whether the city council has a legal basis to obtain this information. Data on the date of birth, professional category, type of contract and date of termination of the contract of the employees of the concessionary company referred to in the inquiry shall be considered personal data, even if provided separately of the first and last names of the working people. The city council has an authorization or legal basis to receive this information from the concessionaire given the provisions derived from both the local regime regulations and the public procurement regulations. However, the delivery must comply with the rest of the principles of the data protection regulations, in particular the principle of minimization, so it is not justified to include the first and last names of the working people affected.

The Town Council, in attention to the competences that it has attributed on the subject of management of waste, would be legitimated to carry out the data processing described in the phase 1 of implantation of the intelligent system of selective collection. The participation of third, the process of seudonimyzed of the data included, would require the formalization of a contract of person in charge and, if it suits, of sub person in charge of the treatment, like this how, if, the fulfillment of the duties established about this in the LCSP, suits. In any case, to guarantee the efficiency of the seudonimyzed, it would be convenient to revise the process of register in the application for smartphones that will be offered to the users of the service, to articulate it through the assigned code.

Data protection legislation would not prevent the reporting of the work services carried out by members of the urban guard during the year 2019, provided that this information is provided in a pseudonymised manner, without the direct or indirect identification of the workers affected by third parties being possible. The use of the TIP of the urban guard cannot be considered appropriate since it is a numerical code that can easily be known to other municipal workers. This without prejudice to the fact that, subsequently, if there is any justification for this in the light of these reports, the city council can reveal to the trade union representative the identity of the worker concerned, without the need for his prior consent.

The regulations of data protection would not block the access to the amounts perceived monthly by the concepts of complement of productivity and gratifications of the head of the police local during the indicated period. It would block neither the access on the part of one of the workers to the listing of the rest of members of the Local Police, that have of be identified through the identification number (FULL), where the amounts perceived as a complement of productivity figure. However the access to the listing of the amounts perceived in concept of gratifications, should be facilitated through a code which it does not allow to identify for them.

With the information of which it is ordered, and for application of the principle of minimization the transmission in the Town Council of the detail of work information of the workers/nothing of the adjudicator company contained to the Instructions regulatory of the procedure of control of the concession of water supply, should be facilitated of anonymized way or pseudonymized. For the purpose of control of the quality of the service, it does not seem that in this case the identification of the affected workers/nothing is necessary/from.