Data in exchange for "prizes": Ministries and Municipalities in the crosshairs of the Privacy Guarantor

Two investigations involve the Municipality of Bologna, one of which for the Pollicino Project promoted by the Ministries of Ecological Transition and Infrastructure as well as the Foundation for Sustainable Development. Third dossier to be paid by the Municipality of Fidenza 08 Jun 2022 Mila Fiordalisi Director

"Reward" virtuous citizens using data and information apparently anonymized for statistical purposes or allow the accumulation of "points" to be used for the purchases of products of companies: some public initiatives involving Municipalities and Ministries end up in the sights of the Privacy Guarantor. "The interventions were necessary due to the risks associated with profiling mechanisms that involve a sort of "points citizenship" and from which negative legal consequences may derive on the rights and freedoms of the interested parties, including the most vulnerable subjects", explains the Privacy Guarantor in a note in which he points out that the authority "reserves the right to adopt any measures resulting from the results of the ongoing investigations". Index of topics • The case of the Pollicino Project • The Smart Citizen Wallet of Bologna • In Fidenza popular housing "by score" The case of the Pollicino Project An investigation concerns the "Pollicino Project", an experimental statistical survey – promoted by the Foundation for Sustainable Development, the Ministry of Ecological Transition and the Ministry of Sustainable Infrastructure and Mobility – through which the citizen is invited to share their data (apparently "anonymously"), to allow an analysis of mobility. At the end of the survey, it is expected that the citizen will receive prizes offered by the private partners of the Project. The survey will be the first to involve the Municipality of Bologna. The Authority has asked for clarifications from the Foundation, the Municipality of Bologna and the Ministries concerned to know, in particular, the role of the public and private subjects involved, the legal basis of the processing, the methods of operation of the app system and the treatments connected to it. The Smart Citizen Wallet of Bologna Another investigation concerns the "smart citizen wallet" initiative of the Municipality of Bologna, in which it is envisaged that citizens can join on a voluntary basis a system that allows them to accumulate "credits" within their "wallet", to be spent by accessing a series of prizes / incentives made available by the Municipality and accredited partners. A Fidenza popular accommodation "a rated" Also in the crosshairs is the project launched by the Municipality of Fidenza, which has introduced, with its own Regulation, the so-called "assignee's card" of public housing housing. Also in this case, there is a scoring mechanism associated with the behavior of the assignees of the accommodation, through a scoring system aimed at recognizing benefits and sanctions, including the termination and / or forfeiture of the lease, with possible prejudicial consequences for categories of vulnerable subjects. In calling on all local authorities to evaluate with the utmost attention any future adoptions of "social scoring" projects or its derivations, the Guarantor reiterates the need for these initiatives to always be anticipated by timely impact assessments and respect the fundamental principles of the EU Regulation.