Garante per la protezione dei dati personali (Italy) - 10309500-n.761
Italy's Garante fines Ministry of Justice €20,000 for public data display.
The Italian Garante per la protezione dei dati personali has fined the Ministry of Justice €20,000 for publicly displaying the names and test results of 1,229 notary candidates in the Ministry's entrance hall. The authority found the Ministry lacked a legal basis for this broad disclosure and violated data minimization principles by including dates of birth and test scores, which were not necessary for announcing successful candidates.
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The lesson from this incident
Full lessonThe Italian Ministry of Justice publicly displayed the names, dates of birth, and test scores of 1,229 notary candidates in its entrance hall without a valid legal basis for such broad disclosure. This violated the GDPR's data minimization principle, which requires that only data strictly necessary for the stated purpose be processed and shared. Publishing excessive personal details — including birth dates and test results — went far beyond what was needed to inform candidates of their pass/fail status. This incident demonstrates that physical and administrative data handling practices carry the same legal weight as digital ones. Organizations must assess the lawfulness and proportionality of every data disclosure, regardless of its medium.