According to the general data protection regulation, can the condominium administrator publish the full names of the condominiums and their floors and payment of the condominium fees in the lobby of the building? Can you provide personal data to other people?
The condominium management cannot publicly provide or disclose the tenants’ data, namely to third parties, without their prior authorization.
In fact, this rule does not occur following the application of the General Data Protection Regulation (GDPR). It previously applied and whenever the sharing of personal data goes beyond the management of the condominium and invades the private life of the owner.
Placing a listing at the entrance to the building with the debtors’ names is therefore an overshoot to this rule. Although it seems like a good idea, it should be borne in mind that there are courts that disagree, considering it a defamatory practice. CNPD has also spoken out, since it considers that the names are not accessible only to the tenants, but to all the people that circulate in the building and that is why the right to privacy and good name are violated.
Although, as mentioned, these rules already exist, the regulation reinforces the right to protection of the rights of the holders of personal data, ensuring greater control and more information about the treatment that is carried out by the various entities responsible for its processing.
In this sense, can it be said that a condominium administration made up of residents of a building is equated, for the purposes of this Regulation, with an entity responsible for data processing? In fact, it appears that the condominium administration has access to personal data of all the tenants of the different fractions such as, for example, full name, identification number, bank details (IBAN etc.) as well as specific information regarding expenses, payment of condominium shares, amounts owed, etc., and that, therefore, it is also covered by the Regulation and all its precepts.