- Enforcing jurisdiction
- Italy · Geography does not establish applicable law.
- Confirmed applicable legislation
- Privacy topics
Myndoor S.r.l. – Violation Found (Italy, 2026)
Myndoor S.r.l. was investigated for using a system that analyzes employee messages to assess their stress levels. The Italian data protection authority found that while the company did not violate GDPR, it warned that future processing could lead to issues. This case highlights the need for companies to ensure their AI systems comply with data protection laws.
What happened
Myndoor S.r.l. used a plug-in to analyze employee messages for stress levels without violating GDPR.
Who was affected
Employees whose messages were analyzed by Myndoor's sentiment analysis system.
What the authority found
The authority concluded that Myndoor did not violate GDPR but warned about potential future risks.
Why this matters
This case shows that even if no violation occurs, companies must be careful with AI systems to avoid future compliance issues. Businesses should review their data processing practices to ensure they align with GDPR requirements.
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Source checks
Secondary-source text retrieved.
Automated check recorded — 3 June 2026.
Processing notes: national law identified, scope corrected.
Retrieved text may be a secondary summary or an announcement. These automated statuses do not establish that the original decision was read or that the record received an independent legal review. How we check sources
Myndoor S.r.l. (the controller) is a workplace consulting company. The controller offers a plug-in system that carries out sentiment analysis of messages exchanged by employees (data subjects) that activated the plug-in. The system used AI to analyse the content of messages sent between data subjects in order to assess their stress levels, and generated a report on a weekly basis. The DPA initiated an ex-officio investigation following press reports on the controller. During its investigations, the controller stated that it currently only provided the service to one company, and that the report was only compiled if a minimum number of data subjects used it. In addition, the controller argued that the report covered the entire workforce of a company to prevent employees from being identified. Finally, the controller argued that the system only processed information provided by the data subject (such as names and contact information), and that sensitive and usage data was anonymised. The DPA first clarified that the company providing the system acted as a controller in relation to the data subjects, and not the employers who purchased the system. According to the DPA, employers are technically prohibited from accessing the data processed by the controller to provide the service, and would in any case lack the valid legal basis to do so under the GDPR. While employers can receive reports of the data subjects’ stress levels, the DPA concluded that the employer in question did not have sufficient information to identify the data subjects involved.The DPA compared this to employers entering into a contract for the provision of benefits and services to employees (such as health insurance or access to psychological counselling services). The DPA also emphasised that the controller has the obligation to comply with the GDPR from the design phase (Article 25 GDPR). In addition, the controller must comply with national provisions that prohibit employers from collecting data that is irrelevant to work activities ([https://www.garanteprivacy.it/documents/10160/0/Codice+in+materia+di+protezione+dei+dati+personali+%28Testo+coordinato%29 Article 113 of the Code]). If this provision is not complied with, the processing is not lawful under Article 88(2) GDPR. The DPA also noted that the controller must also comply with [https://eur-lex.europa.eu/eli/reg/2024/1689/oj/eng Article 5(1)(f) of the AI Act], which expressly prohibits the use of AI systems to infer the emotions of a data subject in the workplace. The DPA highlighted that AI systems can generate further inferences in relation to the data originally processed that may not be understandable or verifiable. Therefore, aspects such as model reliability, quality of the data, transparency and explainability are essential conditions to prevent processing activities that are invasive and non-compliant with the GDPR. It is also essential that companies take a prudent approach when adopting AI systems. The DPA did not find a violation of the GDPR, as the controller did not transfer the data to employers, and the company that received the report was unable to identify specific data subjects. However, the DPA issued a warning, as it could not rule out that the processing activities were likely to infringe the GDPR in the future. The DPA was concerned of the possibility that companies and entities could, in the future, identify data subjects from the reports provided by the controller. This would result in a violation of Articles 5, 6, 9, 24, 25 and 88 GDPR, and [https://www.garanteprivacy.it/documents/10160/0/Codice+in+materia+di+protezione+dei+dati+personali+%28Testo+coordinato%29 Article 113 of the Code]. Therefore, the DPA ordered the controller to implement measures to prevent it from disclosing data from data subjects to their employers in any way, even indirectly.
Outcome
Violation Found
The DPA found a violation but did not impose a fine.
Related Enforcement Actions (0)
No other enforcement actions found for Myndoor S.r.l. in IT
This is the only recorded action for this entity in this jurisdiction.
Details
Decision Date
14 May 2026
Authority
Garante per la protezione dei dati personali
GDPRhub ID
gdprhub-10036About this data
Cite as: Cookie Fines. Myndoor S.r.l. - Italy (2026). Retrieved from cookiefines.eu
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