In the past years, the Italian Data Protection Authority (Garante per la Protezione dei dati personali) has made clear statements towards big technology companies introducing their services in Italy, prior to the verification of GDPR and Italian Data Protection Act compliance. We are referring to the Clearview case of 2022, that caused a fine of […]
Francesca Romana Di Costanzo
Posts by Francesca Romana Di Costanzo:

UK Data Protection Commissioner (ICO) launched a Data Protection Audit Framework
The ICO has recently issued an instrument to support organisations in verifying data protection compliance. The online audit toolkits can be used to conduct both consensual and compulsory audits. The toolkits are designed for organization personnel having familiarity with data protection compliance or data protection professionals (for example: senior management, the data protection officer, internal […]

Email Marketing Compliance in Canada: Key Requirements for B2B Communication
In today’s digital landscape, email marketing remains one of the most effective tools for businesses to connect with clients and partners. However, ensuring compliance with local data protection and anti-spam laws is essential to avoid legal complications. For businesses operating in or communicating with recipients in Canada, the Canada’s Anti-Spam Legislation (CASL) and other data […]

Data Protection Officer (DPO) in Singapore – obligations, role and responsibilities
The Personal Data Protection Act (PDPA) of Singapore mandates organizations to safeguard the personal data they collect, use, or disclose. A key aspect of this responsibility is appointing a Data Protection Officer (DPO) or a team to ensure compliance with the PDPA. Appointing a DPO – requirements and obligations As part of the Accountability Obligation, […]

How to verify the implementation of Binding Corporate Rules? The CNIL published a monitoring tool
A number of multinational companies operating across multiple jurisdictions and sharing personal data between different countries, have adopted Binding Corporate Rules (BCRs) as a transfer mechanism under Art. 47 of the General Data Protection Regulation (GDPR). BCRs are internal data protection compliance rules to ensure that personal data transferred between their entities, particularly from the […]
How to protect data from web scraping? Guidelines from The Italian DPA
The Italian Data Protection Authority (Garante per la protezione dei dati personali, or short Garante) has released in May 2024 guidelines aimed to protect personal data published online by public and private entities (in a role of data controller) from web scraping performed by third parties. While the purposes to perform data scraping or web […]
Italian Data Protection Authority imposed the highest fine so far on electricity provider
Telemarketing activities and aggressive practices against the consumers are again in the spotlight of the Italian Data Protection Authority (Garante), that imposed the highest fine ever on the Italian electricity provider Enel Energia. It is unfortunately very common that Italian consumers are harassed by unwanted telephone calls from marketing agencies proposing contracts for different services […]
Unlawful use of a GPS tracking tool installed in company cars was found by the Austrian DPA
The installation of a GPS tracking tool on the company fleet cars has always been a pretty delicate and sometimes controversial topic, on which data protection implications have a critical role when deciding the way it is implemented, in accordance with the principles of privacy by design and by default. The case of the Austrian […]
Insurance company receives significant fine from Swedish SA
Another significant fine for the lack of adequate security measures on personal data was recently issued by a European Supervisory Authority (SA) to a controller responsible for private customers´ data. In the present case, the Swedish Supervisory Authority (IMY) imposed a fine of SEK 35 million (approx. EUR 2.9 million) to the insurance company Trygg-Hansa, […]
Update of the Application for Approval and Guiding Principles for the Controller Binding Corporate Rules (BCR-C)
On the 20th of June 2023 the European Data Protection Board (EDPB) adopted the recommendations 01/2022 on the application for approval and on the elements and principles to be found in the Controller Binding Corporate Rules (BCRs or more specific BCR-C, Art. 47 GDPR). The decision to update some of the principles and guidelines to […]
Italian DPA imposes €240,000 fine on Benetton Group
In April 2023 the Italian Data Protection Authority (Garante per la protezione dei dati personali) has fined the famous fashion brand Benetton with 240,000 Euros for violations of the GDPR related to marketing practices involving consumer data. The Garante’s investigation started in 2019 during the course of a scheduled investigation related to marketing activities and […]
The EDPB releases report of the outcome of the cookie banner task force
Following the massive number of draft complaints (over 500) to companies implementing allegedly unlawful cookie banners issued in May 2021 by the non-profit organization NOYB, the EDPB decided to set up a task force composed of delegations of the EU Supervisory Authorities (SAs) to coordinate the response to complaints filed with several European SAs by […]
The priorities set by the Belgian Data Protection Authority for the 2023 Agenda
At the end of last year, in the context of setting the 2023 budget, the Belgian Data Protection Authority (Autorité de protection des données/ Gegevensbeschermingsautoriteit or APD) has highlighted the main topics that will be the focus of this year’s agenda, depending on the capacity of the authority, as the APD mentioned in its press […]
Over €500.000 fine for a German e-Commerce company having appointed a DPO with a conflict of interest
The fine has been issued by the Berlin Supervisory Authority (Berliner Beauftragte für Datenschutz und Informationsfreiheit – BlnBDI) on the 20th of September to an e-Commerce company following to the identification of a conflict of interest among the roles of the appointed Data Protection Officer (DPO), as mentioned in the authority’s press release. The DPO […]
Spanish Supreme Court: Data subjects can submit their complaint directly to a supervisory authority
According to a decision of the Spanish Supreme Court (Tribunal Supremo) of July 2022, filing a request to exercise the data subject rights with the data controller is not a prerequisite for filing a complaint to the relevant Supervisory Authority for an alleged breach of the GDPR. The decision was issued after a complaint of […]