Court case 6806/2023 – Court Ruling (Italy, 2023)

Court Ruling
DPA CassCiv7 March 2023Italy
final
Court Ruling

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.

Italy's Court of Cassation ruled on a case where a man wanted an old online article about his criminal past removed. The court found that while the article was removed, the man was not entitled to damages because the article was not deemed unnecessary for public debate. This case highlights the complexities of the right to erasure, especially for content published before GDPR.

What happened

A man requested the removal of an old online article about his criminal past and sought damages after it affected his personal life.

Who was affected

The man whose past criminal conviction was revealed to his friends and girlfriend through an old online article.

What the authority found

The court decided that the right to erasure requires a significant change in the person's situation and that the article's removal did not warrant damages.

Why this matters

This ruling clarifies that the right to erasure under data protection laws requires a clear change in personal circumstances. It also underscores that content published before GDPR may not automatically be subject to the same rules, affecting how historical articles are handled.

GDPR Articles Cited

Art. 17 GDPR
Decision AuthorityCass.Civ.
Full Legal Summary
Detailed

The data subject was tried and convicted in a criminal proceeding. He served his sentence in prison and started a new life afterwards. He found a job, made new friends and was in a romantic relationship. After some time, his girlfriend and friends became aware of the data subject’s criminal past through an article published on an online newspaper 18 years before the facts at issue. Shocked, they decided to cut any relationship with the data subject. The data subject asked the controller the removal of the content, which was no longer necessary to pursue journalistic freedom to inform, and compensation for damages suffered due to the publication. The controller removed the article, but refused to compensate the data subject. The controller objected that it did not have an obligation to remove all the contents from its website that were no longer relevant for the public debate. The court of first instance upheld the controller’s view and rejected the data subject’s claim for damages. As the facts dated back to a time when the GDPR was not yet in force, the Court of Cassation denied that the Regulation was applicable at the facts at issue. To the contrary, Directive 95/46/EC regulated the matter. However, the legal reasoning developed by the court substantially follows the structure of Article 17 GDPR and therefore constitutes a relevant interpretation of such a provision. The Court of Cassation upheld the judgement of first instance. According to the judges, a necessary element in the right to erasure is a gap between a depiction of the data subject which is no longer updated and the current situation of the latter. This gap is assessed from the point of view of the data subject, as they are in the best position to evaluate what does no longer correspond to the present. Therefore, the right to erasure can be activated only by the explicit request of the data subject to the controller. The court also stressed that an excessively broad interpretation of the right to

Outcome

Court Ruling

A ruling by a national court on a data-protection matter.

Related Cases (0)

No other cases found for Court case 6806/2023 in IT

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

Details

Ruling Date

7 March 2023

Authority

DPA CassCiv

About this data

Data: GDPRhub (noyb.eu)
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Cite as: Cookie Fines. Court case 6806/2023 - Italy (2023). Retrieved from cookiefines.eu

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