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Buy tickets at a concert organized by the City Council through the website of a private US-based company.
PS 68/2022
It resolves to sanction the City Council as responsible for three infringements: 1) lack of contract for the processor or equivalent document, 2) lack of information on the ends provided for in art.
26/04/2023
Consideration of corporate email address as personal data
CNS 7/2023
The corporate email address of a city council, since it allows the identification of the account holder, is a personal data protected by data protection regulations. The processing of personal data resulting from the sending of email messages by a public worker, in particular the inclusion of third-party corporate mail addresses and the submission to an external recipient, may be legal if a legal basis (art. 6.1 GDPR) occurs and compliance with the principle of purpose (art. 5.1.b) GDPR is met. According to the system of liability provided for in the GDPR, the responsibility for infringements of data protection regulations rests with the controllers, without prejudice to the consequences of disciplinary proceedings.
25/04/2023
Access to information on the provision of drinking water supply service
CNS 8/2023
In this case, for the information available, access by the applicant to a copy of the users' register of the drinking water supply service in a town planning, supply contracts and receipts liquidated between May 2022 and February 2023 cannot be considered as justified, nor can it be considered to be the personal data that may appear in the accounting register system established during the replacement in the provision of this service. However, there would be no problem, if necessary, in providing him with economic information, broken down and aggregated on the cost arising from the provision of the service, in the terms indicated in the opinion.
11/04/2023
Deenegation of access to information on pay supplements and training of work personnel
IAI 17/2023
With regard to the list of people who have received productivity supplements in the last four years, as well as their amount, criteria and calculation requested, data protection regulations do not prevent access to this information from all employees of the County Council. As regards the list of people who have received the bonuses and/or other salary supplements in the last four years, access is only justified with regard to the workforce who hold high positions, management positions, trust, free appointment, special responsibility, or who involve high levels of pay. However, as far as the rest of the workforce is concerned, access is only justified if this information is provided without identifying by categories and replacing the name and surnames of working people with a code that does not allow them to be identified. With regard to information on the training of workers in the last four years, the personal data protection regulation does not prevent access. We must remember that the person representing the workers is subject to the duty of professional secrecy and secrecy.
03/04/2023
Infringement of the right to information
PS 1/2023
The form of the application in paper format did not include all the information in Article 13 GDPR. The online application form included all the ends of Article 13 of the GDPR, although through a chain of links that made it unreachable and transparent.
28/03/2023
Access to information on the identity of tax debtors
CNS 1/2023
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.
27/03/2023
Denyment of access to information on the remuneration of workers of a city council
IAI 23/2023
The data protection regulations allow, in this case, the union delegate to have access to a copy of the decrees of the mayor's approval of the payroll of the staff of the City Council, prior to anonymization of the data of the public employees concerned and limiting their access, if applicable, to any other information that may appear in the said decrees that exceed the object of their claim, pursuant to the principle of minimization of the data (Article 5.1.c of the GDPR). However, it would be possible to provide the merely identifying information contained in the mayor's decrees relating to the mayor, in the terms that have been set out.
23/03/2023
Archiving the complaint about breaches of data protection regulations in video surveillance in the workplace and the lack of information about the purpose of the processing.
IP 127/2022
The complaint is shelved because there are no rational indications that the facts that have led to the initiation of the procedure have taken place. As regards the duty of information on the purpose of the treatment, compliance has been accredited.
21/03/2023
Denyment of access to information about accidental appointment of the mayor of a city council
IAI 20/2023
The data protection regulations do not prevent access to a copy of the report issued by the Directorate General of the Local Administration, concerning the authorisation of a civil servant to accidentally occupy the position of financial controller in the City Council and to information regarding the supplementary remuneration of this job. However, access to the reports issued by those who have accidentally exercised the intervening function will depend on the personal data that is affected, taking into account its content and the application of the limits relating to data protection referred to in Articles 23 and 24 of the LTTE, in the terms that have been set out.
20/03/2023
Denying access to information about a selective process
IAI 18/2023
Data protection regulations do not prevent the complainant from having access, if he is delegated from a trade union organisation that has the most representative status, to information on training data, professional experience, as well as punctuation with respect to merits and other valorative elements that have been taken into account in the selection process and the scores awarded in relation to the subject. In the event that the complainant does not belong to a union organization that has the most representative status, the information must be limited to the identity of the person selected in a selective process - if applicable, the worker concerned - and the scores obtained in the different merits or tests.
20/03/2023
Total number of pages: 73