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The access of the town councilors to the information of reports of helps that can contain sensitive data, requires to take the purpose of the access into account in order to evaluate the proportionality, without discarding the possibility to give the information in an anonymized way. Regarding the access to the "municipal register of entries and exits", it does not seem that the forecast of article 164.3 a) of the TRLMRLC it can found a generalized access of the town councilors in this Register.

Law 23/1998, of 30 December, d’Estadística of Catalonia authorizes the cession, without consent, of the address datum of the Register of Population of Catalonia to another public administration to l’exercici of the competences legally attributed and for matters in what the address is relevant, as well as to the local police d’un town when its knowledge is necessary for l’exercici of the functions of administrative police attributed by law. Its cession, without consent, to the local police with police purposes is left fitted out by l’article 22.2 of the LOPD, whenever s’efectuï in an individualized way and s’acrediti that is necessary for the prevention d’un real danger for the penal public safety or repression d’infraccions.

It is not necessary to have the previous consent of the members of the police body in order to treat data of location, in accordance with the Instruction 9/2012. However, since there is not work linking with third parties of contact foreign to the police body, it is necessary to have its consent. The data processing of location, has to respect the principles of quality and of purpose and has to be in the corresponding file of public titularity foreseen.

Rejection of the present protection of rights, since the request of previous rectification before the responsible for the file, formulated by a juridical person, could not be considered made under protection of the LOPD applied Articles: article 1, 3rd, 16 LOPD, 23 RLOPD and 105.2 LRJPAC

The implantation of a system of videovigilància with recording of images with purpose of security of the building, without the previous creation of the file through general disposal, constitutes a severe offense. Applied articles: 20, 44.3.a LOPD; 52 RLOPD; 9 Instruction 1/2009

The communication in the INSS of data of the firefighters in situation of second activity is set in the duty of the Administration of communicating the Social Security the relevant information for the exercise of its competences, of avoiding an eventual harm to the public fund, and of collaboration among public administrations. And the sending of information among organs of the same Administration does not constitute a communication of data, it is set in the exercise of the ordered functions, and is proportionate to its accomplishment. Applied articles: Art. 4, 6.2 and 11 LOPD, 37.4, 45.1, 143 and 230.c) LGSS, 4.1.c) and 102 LRJPAC, 113, 114 and 116 of the Decree 243/2007