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Italian #DPA lock down the risky #surveillance law that aim to have (biometric_identification+cctv+smart_image_analisys) to check public employees punch-in and punch-out.
This time DPA analyze implementing decree.
In october 2018 the DPA did the same on the draft of the main law Image
The law is already in force (D.Lgs 56/2019) but it lacks of application rules.

The DPA is highlighting and pointing out all the issues related to the law itself ant to the application rules, that are conflicting with the #GDPR main #principles.
Main issues are:

1) terms and #definitions don't match with GDPR definitions. they have to be lined up
2) principles of #Necessity & #Proportionality are completely unattended
3) the new biometric gates can't be #mandatory
4) #alternative gates should be available if needed
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