SWDE (Société Wallonne des Eaux) – €86,000 Fine (Belgium, 2026)

SWDE (Société Wallonne des Eaux), the controller, was an autonomous Belgian public provider responsible for the management and supply of drinking water in Wallonia. It served around 1.1 million customers and supplied water to around 2.5 million people. To handle customer requests, it operated a general telephone number through a call centre. Simple requests were handled by the Front Office, while more complex or specific requests were transferred to, or handled by, different Back Offices, including the Litigation Department. On 16 April 2020, an employee (the data subject) of the controller filed a complaint with the DPA. Since the data subject was still employed by the controller, they asked the DPA not to disclose their identity to it. The data subject alleged that the controller systematically recorded and monitored incoming and outgoing calls for service quality control and staff training, without sufficiently informing employees about the processing of their personal data. They also alleged that employee files had been transferred to a company outside Belgium and that the recordings were insufficiently secured. The controller stated that it had started recording incoming calls to the Front Office in November 2018 and to certain Back Offices in March 2020, in order to assess the quality of staff responses, train employees and improve its services. It stated that regular recordings had been implemented in the Front Office and in the East and West Back Offices, but not in the central Back Office (Litigation Department). However, recordings had also been considered for this Department. According to the controller, only three test recordings were carried out in the Litigation Department between October and November 2020, to allow the department’s supervisor to test and understand the recording platform. After those tests, the controller decided not to continue monitoring the calls in that department. It stated that this decision had been communicated orally to the e