Emiglia-Romagna Regional Employment Agency

What happened

The Italian DPA has imposed a fine of EUR 30,000 on the Emiglia-Romagna Regional Employmant Agency. In their complaint, the data subject states that, after requesting the deletion and de-indexing of an internal ranking list regarding the recruitment of a technical receptionist, the list still showed up in Google searches of her name, containing her personal data. The list was created in accordance with national equity and inclusion law, and the data subject therefore stated that being on the list could lead to conclusions being drawn about her financial circumstances or disabilities. While the creation of the list was lawful, its publication was not; an anonymised version would have met the controller's need for publication.

Summary from the CMS Enforcement Tracker, not by Fino. CC BY-NC-SA 4.0.

Rules involved

• Art. 5Principles relating to processing of personal dataRead →
• Art. 6Lawfulness of processingRead →
• Art. 9Processing of special categories of personal dataRead →

• Data principles
• Special categories
• Unlawful processing