Clio S.r.l.
Insufficient legal basis for data processing
Fecha de la decisión
21 de julio de 2022
Autoridad
Italian Data Protection Authority (Garante)
IT
Sector
Industry and Commerce
País
IT
Ley
GDPREstado
FINALDescripción
The Italian DPA has imposed a fine of EUR 10,000 on Clio S.r.l.. Clio provides and manages a whistleblowing reporting application for various private and public entities. As part of its investigation, the DPA found that Clio had not adequately regulated its relationship with customers. In addition, Clio provided data on whistleblowing reports to customers without a valid legal basis. The DPA considered this to be a violation of Art. 5 (1) a) GDPR and Art. 6 GDPR. Further, the DPA found that Clio had failed to maintain a register of activity carried out in its role as a processor. The DPA considered this to be a violation of Art. 30 (2) GDPR.