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San Marino: Guarantor issues opinion on exchange of data between public entities

The Guarantor for the Protection of Personal Data ('Guarantor') issued, on 15 April 2021, an opinion in favour of the exchange of data between public entities. In particular, the Director of the Political and Diplomatic Affairs Department of the Foreign Affairs Directorate had requested an opinion from the Guarantor on the processing of personal data of citizens residing outside the territory, in light of the requests from San Marino citizens abroad addressing the consular and diplomatic offices.

Notably, the Guarantor responded with the following recommendations in relation to the transfer of data between public entities:

  • the processing must be lawful pursuant to Article 5 of Law No. 171 of 21 December 2018, Protection of Individuals with Regard to the Processing of Personal Data ('the Law');
  • the controller must comply with the Law and therefore fulfil his/her obligations therein; and
  • the controller must implement technical and organisational measures to ensure a level of security adequate to the risk pursuant to Article 33 of the Law.

You can download the full opinion, only available in Italian, here.