Italian Health Authority Fined €20,000 for Unlawful Publication of Judicial Records
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The provincial Health Authority of Enna published a resolution containing a data subject's judicial records without a lawful basis, violating GDPR's core principles of lawfulness and data minimisation. Compounding the breach, the authority failed to adequately fulfil the data subject's right to erasure, demonstrating weak internal processes for handling sensitive personal data. This case highlights that public bodies handling health and judicial data must apply strict controls over what is published in official documents and maintain clear, enforceable procedures for responding to erasure requests. The financial and reputational consequences of such failures underscore the importance of embedding privacy-by-design practices into document management workflows.
Tactical Insight
Immediate actions
- Conduct an urgent review of all publicly accessible resolutions and documents to identify and redact any unlawfully disclosed personal or judicial data.
- Establish a formal, time-bound process for responding to data subject erasure requests in compliance with GDPR Article 17.
Long-term improvements
- Implement a mandatory privacy review checkpoint before any official resolution or document is published publicly, ensuring data minimisation principles are applied.
- Train all staff involved in document preparation and publication on GDPR obligations, particularly regarding special category and judicial record data.
- Appoint or empower a Data Protection Officer (DPO) to audit publication workflows and enforce compliance standards on a recurring basis.
Detection & response measures
- Deploy a periodic automated or manual audit of publicly published documents to detect residual sensitive personal data.
- Create a documented incident response procedure specifically for cases of unlawful data publication, including takedown steps, notification timelines, and escalation paths.