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Separate Waste Disposal

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Separate Waste Disposal

Having received several reports and claims alleging the violation of privacy rules deriving from the mechanisms implemented by some municipalities in connection with the separate disposal of solid waste and/or with detecting breaches of the relevant administrative rules, the DPA adopted a general provision in 2005 setting out the measures data controllers were to take by having regard, in particular, to the proportionality principle. They include the following:

a) No transparent bags should be used in case of "door-by-door" waste collection;

b) No adhesive labels – including the data subject´s name and address – should be placed on waste containers, in particular if the latter are located in a public street;

c) Waste bags may be marked by a bar code corresponding to the holder´s identification data; alternatively, they may be equipped with chip- or RFID-based tags;

d) The competent inspection bodies may not carry out blanket inspections of the waste bags; such inspections should be performed selectively and only if there are grounds to believe that the waste has been disposed of in breach of the relevant legislation/regulations and there is no other means to identify the alleged offender(s);

e) Names and addresses of the citizens taking their waste to the so-called "ecopiazzole" (environmentally friendly waste disposal areas) for separate waste disposal purposes may be lawfully recorded, albeit on a transient basis.

Provision:

  •  Raccolta differenziata dei rifiuti: indicazioni del Garante - 14 luglio 2005 [doc. web n. 1149822]