Liguria Health Protection Agency – €6,000 Fine (Italy, 2026)

A data subject filed a complaint before the DPA against the Liguria Health Protection Agency (the controller). The data subject was employed by the Ligurian Social and Health Care Agency, however, the organisation was later merged with the controller. According to the data subject, the controller initiated discliplinary proceedings and suspended them based on data collected unlawfully through a tracking system in the company vehicle. The data subject also argued that the controller did not sufficiently inform employees that their location was being tracked through the company vehicles. The DPA received several complaints from other data subjects, and joined the complaints. The controller argued that the geolocation system was a measure to protect its assets, to optimise the management of its vehicles, and to ensure worker safety (e.g. to ensure that an employee followed the route while carrying hazardous materials). The controller argued that it did not process employees’ personal data, as it tracked the vehicles themselves and did not link the vehicle with the employee. Finally, the controller argued that the tracking was in compliance with its workers’ statutes. The DPA first stated that the controller had complied with its information obligations. Following the collective bargaining agreement, the controller informed data subjects of how their data was going to be processed. In addition, the controller had included a notice on how their location data was processed. Therefore, the DPA did not find a violation of Article 13 GDPR. The DPA found a violation of Article 5(1)(c) GDPR. The DPA found that the controller systematically and continuously monitored employees assigned company vehicles, as they were tracked at very frequent intervals without allowing them to deactivate the tracking. The DPA found this frequent tracking particularly detrimental to data subjects’ rights and freedoms, because the controller was able to access real-time information on vehicle m