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Verizon Connect Italy S.p.A. – €30,000 Fine (Italy, 2022)

€30,000Garante per la protezione dei dati personali15 December 2022Italy
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Fine

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Verizon Connect Italy S.p.A. was fined EUR 30,000 for failing to have a proper agreement with a company that used its geolocation services. The Italian data protection authority found that Verizon did not have the necessary legal framework to process personal data. This case serves as a reminder for companies to have clear agreements in place when handling personal data.

What happened

Verizon Connect Italy S.p.A. was penalized for not having a written agreement with Giessegi Industria Mobili regarding data processing.

Who was affected

Employees of Giessegi Industria Mobili, whose geolocation data was processed without proper agreements, were affected.

What the authority found

The authority decided that Verizon violated GDPR by not having a written agreement with the data controller, leading to unlawful data processing.

Why this matters

This case highlights the necessity for service providers to establish clear agreements with their clients to ensure compliance with data protection laws. Companies should review their contracts to avoid similar issues.

Recorded legal citations
Automatically processed
Art. 6 GDPR
Art. 5(1)(a) GDPR
Art. 28(3) GDPR
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Art. 5(1)(a) GDPR
Art. 6(GDPR)
Art. 28(3) GDPR

Original imported citations before automated processing; the processing history does not establish independent verification.

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Full Legal Summary
Detailed

A data subject filed a complaint against Verizon Connect Italy S.p.A., a company providing geolocation services. The data subject claimed to have found a device in the vehicle that they used to deliver goods on behalf of a second company, Giessegi Industria Mobili. The data subject was employed by Giessegi and had no direct relationship with Verizon. Verizon provided geolocation services to Giessegi, which wanted to keep track of its vehicles. The data subject was not informed by the employer about the existence of geolocation devices installed on the vehicle. Therefore, the data subject addressed Verizon, whose name is visible on the device, with an access request. This request did not receive any reply. After examining the defense notes provided by the company, the Italian DPA opened an administrative procedure in order to ascertain potential violations of Articles 5(1)(a), 6 and 28(3) GDPR. During the investigation, Verizon claimed it has no controllership on the processing at issue. In the terms of services signed by Giessegi, Verizon qualified itself as a mere processor of personal data on behalf of Giessegi, which was the true controller. This is also the reason why usually Verizon does not reply to access requests from data subjects but only facilitates access indirectly by providing all relevant data to its clients. In addition, as the agreement with Giessegi expired in 2020, Verizon deactivated its devices and has no longer access to geolocation information. However, the Italian DPA ascertained that a written agreement between Verizon and Giessegi setting up the specific obligations of the processor did not exist. This could lead to a violation of Article 28(3) GDPR. Verizon replied that the obligation to conclude a written agreement between controller and processor is not clearly stated in the GDPR. Such an obligation stems from the [https://edpb.europa.eu/system/files/2021-07/eppb_guidelines_202007_controllerprocessor_final_en.pdf EDPB guidelines 07/2020] on the concepts of controller and processor in the GDPR, which were not in place at the time of the facts. Verizon also stressed that it complied with all the processor´s substantial obligations. On the other hand, no violation of Articles 5(1)(a) and 6 GDPR could be found, as these provisions apply only to controllers. The Italian DPA rejected Verizon´s defense. In the first place, the obligation to conclude a written agreement regulating the rights and duties of the processor clearly stems from Article 28(3) GDPR itself. Besides, as far as the Italian jurisdiction is concerned, the obligation also derives from the case law of the Court of Cassation. According to the Italian DPA, there was no need of further clarifications by the EDPB guidelines. The mere fact that the terms of services between Verizon and Giessegi qualified the former as ´processor´ is not sufficient to meet the conditions established by Article 28(3) GDPR. Since such an agreement between controller and processor did not exist, Verizon was subject to the same obligations applicable to the controller, including Articles 5(1)(a) and 6 GDPR. As a matter of fact, Articles 5(1)(a) and 6 GDPR set general principles and conditions of processing which apply regardless of the qualification of the subject processing data. In this case, processing was manifestly unlawful, as it was not possible to find a legal basis applicable to the facts at issues. Therefore, the Italian DPA found a violation of Articles 5(1)(a), 6 and 28(3) GDPR and adopted an administrative fine on the basis of Articles 58(2)(i) and 83 GDPR. The total amount of the fine took into account the long period of time in which the violation occurred (4 years) and the fact that not only the applicant, but also other Giessegi´s employees were involved. On the other hand, the Italian DPA considered that Verizon cooperated with the authority during the investigation and reduces the sanction accordingly. The final amount of the fine was set at 30.000 EUR.

Related Enforcement Actions (0)

No other enforcement actions found for Verizon Connect Italy S.p.A. in IT

This is the only recorded action for this entity in this jurisdiction.

Details

Fine Date

15 December 2022

Authority

Garante per la protezione dei dati personali

Fine Amount

€30,000

GDPRhub ID

gdprhub-5717

About this data

Data: GDPRhub (noyb.eu)
Licensed under CC BY-NC-SA 4.0
Automatically normalized and classified

Cite as: Cookie Fines. Verizon Connect Italy S.p.A. - Italy (2022). Retrieved from cookiefines.eu

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