OOAA contribution to the public consultation promoted by the Italian DPA on the processing of employee email metadata

We are pleased to share our contribution to the public consultation promoted by the Italian DPA on the processing of employee email metadata.

OOAA’s contribution examines the implications related to the storage of metadata of employees’ email service accounts, such as date, time, sender, recipient, subject and size of the email.
What you will find in the document:

  • The definition of ‘metadata’ and the technical implications of its removal
  • The compliance of the measure with European legislation, in particular the GDPR and the TFEU
  • The compatibility of the measure with national legislation, both at constitutional and primary level.

This contribution is the result of collaboration between our privacy and data protection specialists – Fabrizio Sanna, Marta Minonne, Olga Sihtar – and our labour law specialists – Luca Garramone and Cecilia Biscottini.

The collaboration with the Italian DPA gave us the opportunity to participate in the public debate on key privacy and data security issues.