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Since the communication of data of the files of clinical history was a consequence of a modification in the form of management of the services of mental health and additions, for which a municipal entity would subrogate itself in the position of the other one, it would be necessary, until the RGPD is not fully applicable, to notify the modification of the responsible for these files to the Register of Data Protection of Catalonia and to inform the affected persons of it. This, without harm of the fulfillment of the rest of principles and duties established to the legislation to data protection.

The entities who shape the public sector of the Generalitat de Catalunya are, each of them, responsibles for the treatments of the particulars which they have. The responsibility of the Tributary Agency of Catalonia and of the General Direction of Social Protection in the treatment of these data will depend in the way its communication is articulated, although, for the information of which it is ordered, these could adopt the posture of persons in charge of the treatment, whenever the corresponding contract of order is formalized. In this judgement the fulfillment of some of the duties imposed by the regulations to data protection (obtaining of the consent, duty of information, creation of files and resolution of the procedures of rights exercise) is also analyzed. 

The data processing carried out by the municipal Group, as a responsible (art. 3 d) LOPD), through the recording and posterior diffusion of the intervention of its spokesman, he has to undergo the principles and guarantees of the regulations of data of personal character protection. The municipal Group, with character previous at the beginning of the treatment, it should create the corresponding file of data (article 20 LOPD), by agreement of the same municipal Group, in accordance with what foresees the article 52 of the RLOPD, to publish it and to notify it to the Register of Data Protection of Catalonia, in accordance with the article 11 of the Law 32/2010.

The use of devices GPS in the police vehicles it entails the data processing personal and, therefore, is subjected to the regulations of protection of particulars. If the treatment is carried out to ensure the normal functioning of the service, the Town Council would not need to have the previous consent of the affected ones, peró yes that it should fulfill the duty of information and the duty to creation (or modification) and notification of the file that contains the data of geolocation.

The files of the Consortium, like entity of public law of associative character, with own legal status, ascribed to the Generalitat, are considered files of public titularity, on being the responsible that it shows the titularity an entity for public law. Any modification or suppression of these files or the creation of others of new has to be notified to the Catalan Authority of Protection of Data for its inscription.

The files of the urbanistic entities of conservation linked to a Town Council or another performing administration that is part of the area of performance of the APDCAT also are included in the area of performance of this Authority and, therefore, can be set in the Register of Data Protection of Catalonia. Its files are files of given public titularity the administrative nature of these entities.

The purpose of the installation of the system of videovigilància in the dependences from the lender company of municipal public services is legitimate, to be related with the surveillance and the control of the facilities, and the consent is not required from the affected ones (article 6.2 LOPD). The images have to be treated without harm of the considerations made in relation to determinate cameras in the context of the legitimate purpose and not for other purposes incompatible, so that the system of videovigilància fits to the principles of quality and of purpose. The system of videovigilància has to give information in the terms of the article 5 LOPD and 12 of the Instruction, and to comply with the rest of principles and duties to the regulations of data protection.