Comune di Forlì – €15,000 Fine (Italy, 2024)

€15,000Garante per la protezione dei dati personali20 June 2024Italy
final
ePrivacy
Fine

General GDPR enforcement action

This case relates to broader data protection obligations, not specifically to cookie or consent banner compliance. It is not included in cookie statistics or the Risk Calculator.

The Comune di Forlì was fined for launching a mobile app that collected personal data without proper consent. This matters because it shows that even local governments must follow data protection rules. Businesses should ensure they have clear consent before collecting user data.

What happened

The Comune di Forlì launched a mobile app that collected personal data without obtaining proper consent.

Who was affected

Citizens using the app who reported unsafe areas and had their data collected.

What the authority found

The authority found that the Comune di Forlì violated multiple GDPR requirements by not securing user consent for data collection.

Why this matters

This case highlights the importance of obtaining consent for data collection, even for public services. Local governments and businesses alike must review their data practices to comply with privacy laws.

GDPR Articles Cited

AI-verified

Art. 13(GDPR)
Art. 25(GDPR)
Art. 32(GDPR)
Art. 5(1)(a) GDPR
Art. 5(1)(f) GDPR
Art. 5(2) GDPR
Art. 12(1) GDPR
Art. 13(2)(a) GDPR
Art. 28(3) GDPR
Art. 28(9) GDPR
Art. 35(1) GDPR
View original scraped data
Art. 5(1)(f) GDPR
Art. 5(1)(a) GDPR
Art. 5(2) GDPR
Art. 12(1) GDPR
Art. 13(GDPR)
Art. 13(2)(a) GDPR
Art. 25(1) GDPR
Art. 28(3) GDPR
Art. 28(9) GDPR
Art. 32(GDPR)
Art. 35(1) GDPR

Original data from scraper before AI verification against source document.

Source verified 5 April 2026
articles corrected
Full Legal Summary
Detailed

The controller is an Italian municipality which decided to implement a mobile application. This application was made available on app stores between December 2020 and January 2021. It allowed citizens to send notifications to the Local Police about unsafe areas. After getting this notification, the Police could use the video surveillance system to monitor the area. Therefore, personal data of both the person who made the report and the people recorded by the camera were collected. The software collected the phone number of the reporting person and the location data. The former was then stored for 7 days, allowing the Police to contact the person to get more details about the incident. After 7 days, only location data was kept in an anonymised way. The controller decided not to manage this app on itself, but to outsource the development and the management of both the app and the video surveillance system to a company which is owned by the municipality. The application was temporarily deactivated from April to June 2022. On 11 July 2022 it was permanently deactivated, after the DPA started an investigation on the matter. Firstly, the DPA pointed out that the controller made the application available on app stores even though it was still in a beta version and, therefore, had not been completely tested yet. Moreover, the controller kept using the app even though the DPO had warned it about the data protection pitfalls of this processing. In addition, the DPA highlighted that, in the first release of the app, users could freely make a report, without the situations that could potentially be the subject of a report being predetermined. In the second release, the controller added a predefined list of categories to classify the report. However, users were still able to send a report of an “undefined” type. The DPA noted that this could lead to the collection of non-necessary data or data falling under Articles 9 or 10 GDPR. Moreover, it was also possible to make a report

Violations (1)

Cookies Placed Before Consent
critical

Non-essential cookies (tracking, advertising) are placed on the user's device before obtaining valid consent.

Art. 6(1) GDPR

Related Enforcement Actions (0)

No other enforcement actions found for Comune di Forlì in IT

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

Details

Fine Date

20 June 2024

Authority

Garante per la protezione dei dati personali

Fine Amount

€15,000

GDPRhub ID

gdprhub-8066

About this data

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

Cite as: Cookie Fines. Comune di Forlì - Italy (2024). Retrieved from cookiefines.eu

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