On 18 September 2025, the French Data Protection Authority (CNIL) issued Deliberation SAN-2025-008, imposing a €100,000 fine on Samaritaine SAS for clandestinely installing surveillance cameras in employee areas. In August 2023, in response to a rise in stockroom thefts, the company installed five hidden cameras disguised as smoke detectors. The devices also recorded audio. Within […]
Giulia Provini
About Giulia Provini
Posts by Giulia Provini:
Automated Credit Scoring Under Scrutiny in Europe
The CJEU’s SCHUFA judgement (C-634/21) in 2023 clarified that producing and transmitting a credit score can itself amount to an automated decision under Article 22 GDPR where the score is determinative for contract outcomes. This ruling has now translated into concrete enforcement. In 2025, both the Austrian and Hamburg DPAs issued decisions that apply these […]
Pseudonymised Data: Not Always Personal According to The Latest CJEU Judgement
On 4 September 2025, the Court of Justice of the European Union (CJEU) handed down its judgment in EDPS v Single Resolution Board (C-413/23 P). The ruling addresses a fundamental question in EU data protection law: when pseudonymised information qualifies as personal data, and for whom. This decision provides important clarification on the scope of […]
UK Data (Use and Access) Act 2025: Key Changes for Privacy Compliance
On 19 June 2025, the Data (Use and Access) Act 2025 (DUAA) received Royal Assent, becoming law in the UK and marking a significant development in the country’s data protection framework. The first provisions will take effect on 20 August 2025 under the Commencement No. 1 Regulations, with others phased in through mid‑2026; some changes (most […]
Enforcement Trends in DSR Handling: Key Lessons from Recent EU Decisions
Over recent months, data protection authorities have issued rulings that expose common failings in the handling of data subject rights requests (DSRs). While these were isolated complaints, the supervisory authorities found that the organisations involved lacked internal procedures, failed to provide legally reasoned responses, and could not demonstrate accountability when challenged. These rulings confirm that […]
Preventable Data Breaches: Compliance Takeaways from Recent ICO Cases
Over the past few months, the UK Information Commissioner’s Office (ICO) has issued a series of enforcement actions that underscore a recurring regulatory concern: data breaches that, in the ICO’s view, were not merely accidental but the result of organisations failing to implement even basic data protection safeguards—violations of their accountability obligations under the UK […]
DPO Independence Is Not Optional: Key Takeaways from the Italian DPA
In a decision dated December 2024, the Italian Data Protection Authority (Garante) imposed a fine of 70,000 euros on a credit rehabilitation company for multiple violations of the General Data Protection Regulation (GDPR). While the monetary penalty addressed several issues—such as unlawful data retention and the absence of processor contracts—the most significant takeaway is the […]
Garante Fine for Employee Monitoring and GPS Tracking
The Italian Data Protection Authority (Garante) recently issued a significant decision, imposing a fine of 50,000 euros on a company for unlawful employee monitoring through GPS tracking systems. The sanction followed an investigation into the company’s failure to comply with both national labour law and the EU General Data Protection Regulation (GDPR)—despite having received prior […]
Website Accessibility in Italy
Website accessibility is becoming an increasingly important topic in Italy, in particular since companies have until the 28th June 2025 to comply with the new European Accessibility Directive. In this article, we outline the Italian legal framework for website accessibility, the importance of early action, and practical steps businesses can take to ensure compliance and […]
Navigating Employee Email Privacy: Lessons from a recent Fine by Italy’s DPA
The Italian Data Protection Authority (Garante) recently imposed a significant fine of 80,000 euros on a company, for mishandling a sales agent’s email data, highlighting once again the challenges and complexities of managing employee data, in particular when access to employees’ emails is required. The issue arose when the company used a backup of the […]
Legitimate Interest: new CJEU ruling challenges Dutch Authority’s strict interpretation
On October 4, 2024, the Court of Justice of the European Union (CJEU) issued a ruling in the case C-621/22, addressing whether purely commercial interests can qualify as a legitimate interest for processing personal data under Article 6 para. 1 lit. f of the General Data Protection Regulation (GDPR). This decision challenges the strict stance […]
AI and HR – Navigating legal obligations in Europe
Artificial Intelligence (AI) is reshaping HR and recruitment practices worldwide, promising enhanced efficiency and precision. While the adoption of AI in HR is not groundbreaking news, as many large companies have relied on similar solutions for years, its undeniable benefits continue to drive organizations of all sizes towards embracing AI-powered tools. Technologies like resume screening […]
Retention of Metadata – legal and business impacts of the Italian DPA guideline – UPDATED
A few months ago, we delved into a new decision of the Italian data protection authority (Garante) on this blog, which recommended that employers set retention periods for their employees‘ email metadata not exceeding 7 days. This guideline created some confusion, leading the Garante to suspend its applicability and open it up for public consultation […]
Privacy and AI: Schufa algorithm condemned by the CJEU
In December 2023, the Court of Justice of the European Union (CJEU) issued Judgement C-634/21 on the Schufa case. This landmark ruling is set to shape the GDPR-friendly approach to future AI-based businesses. At a pivotal moment where AI takes center stage in the European Institutions’ agenda, with efforts towards the adoption of the renowned […]
Seven days to retain metadata – legal and business impacts of the Italian DPA decision
Indiscriminate and unrestricted retention of employee data (especially their emails) is a common yet dangerous violation of the GDPR that undermines workers‘ rights from multiple perspectives. But how far can GDPR compliance go without excessively hindering business needs and interests? This is the question behind one of the most recent (and discussed) decisions of the […]
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