Regione Lazio
€75,000
Insufficient data processing agreement
Decision Date
January 14, 2021
Authority
Italian Data Protection Authority (Garante)
IT
Sector
Public Sector and Education
Country
IT
Law
GDPRStatus
FINALDescription
The Italian DPA (Garante) has fined Regione Lazio (Lazio Region) EUR 75,000 for failing to designate Capodarco, the company it entrusted with the management of reservations for healthcare services in 1999, as a data processor. The controller had not entered into a contract with Capodarco that would have governed its role as data processor in accordance with the requirements of data protection law. Thus, a proper contract for commissioned processing had not been concluded until 2019, which meant that data had been processed unlawfully for a period of about 20 years.
Legal Citations
Art. 5 (2)Art. 28
Issues & Violations
Insufficient data processing agreement