USB Lavoro Privato Puglia – €50,000 Fine (Italy, 2025)
General GDPR enforcement action
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USB Lavoro Privato Puglia was fined for improperly handling employee interviews about their return to work. This is important because it raises concerns about employee privacy and how companies collect sensitive information. The company must change its practices to comply with data protection laws.
What happened
The company conducted return-to-work interviews without ensuring proper data protection measures.
Who was affected
Employees who participated in the return-to-work interviews and shared personal health information.
What the authority found
The authority determined that the company violated GDPR rules by not adequately protecting sensitive employee data during the interviews.
Why this matters
This ruling emphasizes the need for companies to handle employee data carefully, especially when it involves health information. Businesses should review their data collection practices to ensure compliance.
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An automotive company (Magna PT S.p.A., the data controller) asked its employees (the data subjects) to undergo “return to work interviews” (“RTWI”) upon returning after leave. Interviews were carried out by the direct superior of the data subjects. The purpose of the interview was to support data subjects in their return to their workplace and gather information on possible shortcomings of the working environment in order to later address them. The questions included, among others, whether the employee's leave was caused by their work, whether their health condition got worse in time, and whether their doctor prescribed specific accomodations or limitations. The controller claimed that participation in the interview was voluntary. Answers given in the interview were manually transcribed in a form and forwarded to HR. HR would then assess the modules and consider possible action to address any issues, along with the data subjects’ superior or the company doctor. Forms were stored for a maximum of ten years. In practice, the controller periodically reviewed the forms and destroyed the ones it did not consider relevant anymore. At the time of the investigation, no form had been stored for longer than 1 year. In 2021 a workers’ union (USB Lavoro Privato Puglia) challenged the lawfulness of this practice by filing a complaint with the DPA. The DPA investigated the complaint two years later. The DPA held that the controller violated Articles 5(1)(c)(e), 6, 9, 13 and 88 GDPR as well as Article 113 of the Italian privacy code. The DPA issued a €50,000 fine and ordered the erasure of the subjects’ data. = The controller stated that the processing relied on the legal basis of consent. In this regard, the controller observed that while consent cannot generally be freely given by employees, EDPB and WP29 Guidelines leave some room for consent when the employee's refusal has no negative consequences for the employee. The controller argued that this was precisely the case of
Violations (1)
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Art. 6(1) GDPR
Related Enforcement Actions (0)
No other enforcement actions found for USB Lavoro Privato Puglia in IT
This is the only recorded action for this entity in this jurisdiction.
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Details
Fine Date
10 July 2025
Authority
Garante per la protezione dei dati personali
Fine Amount
€50,000
GDPRhub ID
gdprhub-9438About this data
Cite as: Cookie Fines. USB Lavoro Privato Puglia - Italy (2025). Retrieved from cookiefines.eu
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