Autonomous Province of Bolzano/Bozen – €32,000 Fine (Italy, 2025)

€32,000Garante per la protezione dei dati personali25 September 2025Italy
final
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 Autonomous Province of Bolzano was fined for using cameras to collect license plate data without getting proper consent. This is important because it shows that even government entities must follow data protection laws. Businesses should be aware that collecting personal data requires clear consent from users.

What happened

The Autonomous Province of Bolzano installed cameras that collected license plate data without obtaining user consent.

Who was affected

Drivers whose license plates were captured by the cameras were affected.

What the authority found

The Italian data protection authority ruled that the province violated GDPR by not obtaining consent for processing personal data.

Why this matters

This ruling emphasizes that consent is crucial for data collection, even in public spaces. Organizations should ensure they have proper consent mechanisms in place before collecting personal information.

GDPR Articles Cited
Automatically processed
Art. 13(GDPR)
Art. 26(GDPR)
Art. 35(GDPR)
Art. 5(1)(a) GDPR
Art. 6(1)(c) GDPR
Art. 6(1)(e) GDPR
Art. 6(2) GDPR
Art. 6(3) GDPR
Art. 12(1) GDPR
Art. 21(4) GDPR
View original scraped data
Art. 5(1)(a) GDPR
Art. 6(1)(c) GDPR
Art. 6(1)(e) GDPR
Art. 6(2) GDPR
Art. 6(3) GDPR
Art. 12(1) GDPR
Art. 13(GDPR)
Art. 21(4) GDPR
Art. 26(GDPR)
Art. 35(GDPR)

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

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Full Legal Summary
Detailed

In 2019, the Province of Bolzano (the controller) installed a network of 124 cameras aimed at analysing traffic flows as a basis for mobility and infrastructure policies in a UNESCO protected area. These cameras automatically read license plates, and also collected a series of metadata, including an identifier of the camera, date, time, class of the vehicle, its nationality, KEMLER identifier if present (relates to dangerous goods), and speed of transit. The license number immediately went through a double pseudonymisation process, with the license number being deleted within 60 seconds of its acquisition. The metadata on the other hand was stored for 2 years. The processor, which was the company providing the technology, was the only entity with access to the raw data and to the algorithm used. The controller only had access to the final aggregated data. The Province stated that the level of pseudonymisation in use means that they were not dealing with data that could be classified as personal data anymore. The DPA came across the facts through news outlets, and opened an investigation ex-officio. The Italian DPA held first of all that license plates are to be classified as personal data, even if pseudonymised. In fact, anyone could connect them to a natural person by consulting the public vehicle registry. It is irrelevant that this is not the intention of the controller. Referring to the pseudonymisation process put in place by the controller, the DPA pointed out that pseudonymised data is still considered personal data, as they could still be attributable to a natural person when read in conjunction with supplementary information. For example, the stored metadata could be used in this regard. It is also irrelevant that the license number is only stored for 60 seconds, as the duration of processing has no influence on the assessment of its lawfulness. The province, through its processor, was thus processing personal data and needs to comply with GDPR obli

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 Autonomous Province of Bolzano/Bozen in IT

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

Details

Fine Date

25 September 2025

Authority

Garante per la protezione dei dati personali

Fine Amount

€32,000

GDPRhub ID

gdprhub-9620

About this data

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

Cite as: Cookie Fines. Autonomous Province of Bolzano/Bozen - Italy (2025). Retrieved from cookiefines.eu

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