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The data protection regulations do not prevent the person from claiming access to the list of appointments made from 19 June 2019 until the date of the petition, in relation to the last scale of 19 February 2019, of persons who come from the requested work bags, identifying these persons with their name and surnames and four figures of the number of their national identity document determined according to the guidelines published by the APDCAT.

Taking into account the principle of minimization, it cannot be considered that article 15.1.e) of the LTC is a sufficient enabling rule for the City Council to disseminate in the examined case the identity of the monitors and the amount received by them, as individualized, in compliance with the obligation of active advertising. This is without prejudice to the fact that the City Council must access the identity of the monitors hired by the AMPA and the remuneration received for the control of the subsidy.

Outside the cases of direct access to municipal information by the councillors referred to in articles 164.2 of the TRLMRLC and 40 of the ROM, access to municipal information requires a prior weighting that allows the councillors to communicate the data strictly necessary to achieve their functions of control and control of the municipal performance, so direct access to the municipal documentary manager as requested by the requesting councillors cannot be admitted.

The data protection rules do not prevent representatives of the workforce from having access to information on the decision on recognition of the upper category and the salary supplement, as well as the reasons for this, which is not the case with regard to the other information contained in the files. Since the file does not provide proof of the status of worker representative of the person requesting the information, it should be noted that if this condition of the applicant is not certified, the information can only be provided after anonymisation, and provided that the concurrent circumstances do not allow the persons concerned to be identified directly or indirectly without disproportionate efforts.

The data protection regulations do not prevent the access of labor representatives to the information related to the decision to recognize a higher category and the salary supplement, as well as the reasons that justified it, this not being the case with regard to the rest of information contained in the files. Given that the status of labor representative of the person requesting the information is not proven in the file, it must be taken into account that if this status of the person requesting the information is not proven, the information can only be provided prior anonymization, and provided that the concurrent circumstances do not allow the affected persons to be identified directly or indirectly without disproportionate efforts.

With regard to certificates qualified for public workers, in terms of the right to data protection, we should consider the possibility of establishing a certification policy providing for the use of these certificates based on pseudonyms. It is recommended to take into account the various options proposed in this opinion in order to prevent the DNI number from being disseminated in the publication of documents incorporating an electronic signature.

In view of the information available, and taking into account the weighting elements of Article 24.2 of theLTC, data protection regulations would not prevent the information requested on the allowances received by a person who would have held the office of Council President within a certain period of time.

The information requested, relating to the use of plant protection products formulated with 1, 3 Diclorpropene and its mixtures with Cloropicrin, is environmental information and must be applied to the provisions of the LAIA and, in addition, to the provisions not provided for by the LAIA, the forecasts of the LLTC. Data protection regulations do not prevent the claimant from having access to the identification data of public employees, public officials or collegiate technicians that may appear in the requested documentation, nor to information on the number of inspections, controls and sanctions carried out by the claimed administration, with indication, if applicable, of the province and the administrative infringement charged. As far as the other information is concerned, the data that allows natural persons with authorisations to be identified should be omitted, unless these authorisations have a significant effect on the environment. As long as there is a possibility of striking a balance between the two public interests at stake, the request for access made should be met and information provided by removing data from it that allows owners of agricultural activities to be identified.

The identification of the persons interested in the publication of the administrative acts in the procedures for granting subsidies, in accordance with the Seventh Additional Provision of the LOPDGDD, must be determined based on the purpose of the publication. When the publication has the purpose of general publicity of the administrative act, the identification of the interested parties must be done with the first and last name together with the 4 digits of their national identity document, the foreigner's identity number , the passport or an equivalent document (following for the determination of the 4 digits, the criteria of the Provisional Guidance approved by the data protection authorities). When the publication of the administrative act has the sole purpose of notifying the interested persons, their identification must be done with the number of their national identity document, the foreigner's identity number, the passport or an equivalent document.

Data protection regulations do not prevent councillors from having access to the identity of persons who hold stands or commercial premises in the municipal market. With regard to access to the other information that the City Council does not specify in its consultation, it would require a specific analysis in view of the aforementioned principle of minimization.