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Advertising of the identification of persons who sign the collaboration and cooperation agreements of the Government of Catalonia
The transparency regulation lays down the minimum content to be disseminated in respect of the partnership agreements by limiting it, as regards personal data, to information on the name and surname of persons acting on behalf of the parties that sign them.
Broadcast on social media of a municipal group of the contents of the curriculum of a person holding the office of mayor.
The treatment carried out by the denounced municipal group is lawful because the information disseminated on their social networks, pursuant to Article 6.1 f) GDPR - about the satisfaction of legitimate interests, as is freedom of information - had been previously published in the Transparency Portal of the City Council in compliance with Article 57.1 LTC. Furthermore, it should be borne in mind that, although the complainant also complained about the fact that not all the content of his curriculum is published, but only certain extracts are published, this does not represent a violation of the principle of accuracy of the data, insofar as the published information was current and truthful.
Denial of access to information on the monetary perceptions of the political groups of the County Council
The data protection regulations do not prevent the claimant from accessing information on the breakdown of the amounts allocated to each group and on the different expenditure concepts made by the groups during the requested period, for the purposes of controlling the destination of the funds they receive. It also does not prevent access to the supporting invoices for expenses that contain personal data of the councilors, as well as third-party natural persons with whom they have contracted, although it would be necessary to remove from the supporting documents the information that allows to analyze or establish certain relative aspects to the personal life of the person making the expenditure, their personal preferences or establishing certain guidelines of conduct, as well as certain data (such as private addresses or ID number), which are not relevant to achieve the purpose of transparency.
The reasoned report examined may be in line with the concept of administrative resolution of public relevance for the sake of transparency. The LTC requires the anonymization of personal data in the publication and since, in this case, despite this, the affected persons could be identifiable, it would be acceptable to replace it with an anonymized summary of its purpose.
In accordance with the rules on the protection of personal data, the access of the claimant to the full content of the requested files is not justified, given the nature of the personal information of the files and the persons affected. This is without prejudice to the provision of anonymised or pseudonymized information which allows the calculations made in each case to be verified and verified, without allowing the identification or re-identification of the persons affected.
With regard to the positions of trust and the eventual staff of the City Council, given the typology and characteristics of these positions, it is justified from the perspective of data protection, to provide individualized information for the remuneration concepts referred to by the claimant. , together with their identification, level and position they hold. As for the rest of the City Council's employees (staff and civil servants), the data protection regulations do not prevent the provision of information on the basic and complementary remuneration of each job, without identifying the people who occupy.
- SECTORIAL AREA
- Workers' representatives
- TRANSFER OR DISCLOSURE OF DATA
- Workers' representatives
- PERSONAL DATA
- Employees' data
- Public administration
- Local administration
- Right of access to information
- Workers' representatives
- Active publicity
Denial of access to information regarding the financial allocations delivered by the City Council to municipal political groups
The data protection regulations do not prevent the claimant from accessing the information on the amounts allocated to each group and on the different concepts of expenditure made by the groups, for the purposes of controlling the destination of the funds they receive. It also does not prevent access to invoices justifying expenses that contain personal data of councilors as well as third parties with whom they have contracted, although information should be removed from supporting documents to analyze or establish certain aspects related to life. personnel of the person making the expenditure, their personal preferences or to establish certain guidelines of conduct, not relevant to achieve the intended purpose in the terms set out in the legal basis IV.
The data protection regulations do not prevent the individualised information requested by the employee representative from being communicated to the employee, indicating the identity (name and surnames) of the workers affected by the agreement on the absorption of the productivity supplement and the amount this agreement has entailed for each worker.
The complaint against the City Council is archived because the personal data of the complainant listed in a local government board agreement, which was disseminated through whatsapp among the municipality's neighbours, is information that the City Council was obliged to publish by the principle of transparency (Art. 9.1.e LTC).
La identificació de les persones beneficiàries d'ajuts públics durant el termini de 5 anys, deriva del compliment d'una obligació legal i d'una missió en interès públic, de conformitat amb la Llei 19/20214 (art. 15.1.c). Atès l'anterior, aquest tractament és lícit.