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Giulia Provini

Giulia Provini

Senior Counsel

FIRST PRIVACY GmbH

Bremen

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Person checkt Zahlungsflüsse auf Bankkonto mit dem Smartphone.

The Italian DPA's Fine Against Intesa Sanpaolo: Lessons for Access Management and Data Breach Handling

09.04.2026

Giulia Provini

On 26 March 2026, the Italian data protection authority (Garante per la protezione dei dati personali, "Garante") fined Intesa Sanpaolo S.p.A. €31,800,000. This is one of the largest fines the Garante has ever imposed, and it carries clear lessons for a [...]

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A statue of Lady Justice against a blurred background of law books.

When Access Requests Become Abusive: Key Takeaways from C-526/24 Brillen Rottler

27.03.2026

Giulia Provini

The Court of Justice of the European Union (CJEU) has clarified in Brillen Rottler (C-526/24) that, in exceptional circumstances, even a first data subject access request (DSAR) may be refused as “manifestly unfounded or excessive” under Article 12 para. [...]

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Man making an online bank transfer on a laptop.

Unlawful Profiling and Poor Transparency: Key Takeaways from the Garante’s Fine Against Intesa Sanpaolo

25.03.2026

Giulia Provini

The Italian Data Protection Authority (Garante) has imposed a €17.6 million fine on Intesa Sanpaolo, one of the largest banking groups in Italy, for unlawful processing of personal data affecting approximately 2.4 million customers in the context of their [...]

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View of a soccer match in a stadium at night under floodlights.

Spanish AEDP v FC Barcelona: DPIA Required for Processing Biometric Data

20.03.2026

Giulia Provini

The Spanish Data Protection Authority (AEPD) recently imposed a €500,000 fine on Fútbol Club Barcelona for failing to properly conduct a Data Protection Impact Assessment (DPIA) when implementing biometric systems used during the club’s membership censu [...]

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Woman walking through the city center with a phone in her hand. Facial recognition around her face.

Biometric Data: Key GDPR Lessons from an AEPD Decision

18.03.2026

Giulia Provini

The Spanish Data Protection Authority (AEPD) recently imposed a €950,000 fine on a company offering digital identity and age verification services that rely on facial analysis technology. The decision is particularly relevant for organisations deploying fac [...]

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Person working with a handheld scanner in a warehouse.

Italian DPA Orders Amazon Entity to Stop Unlawful Employee Data Processing

13.03.2026

Giulia Provini

The Italian Data Protection Authority (Garante per la protezione dei dati personali) has issued an urgent order with immediate effect requiring Amazon Italia Logistica S.r.l. to stop processing personal data relating to more than 1,800 employees at one [...]

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Laptop with symbols for accessibility.

Digital Accessibility and Data Protection: Insights from the Italian Data Protection Authority

11.03.2026

Giulia Provini

Digital accessibility is becoming a central compliance topic across Europe. With the entry into application of the European Accessibility Act (Directive (EU) 2019/882, EAA), EU Member States must ensure that a wide range of digital products and services meet [...]

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Frau nutzt Smartphone zum Online Shopping.

No Account, No Purchase? EDPB Pushes Back on Mandatory Registration

09.02.2026

Giulia Provini

Requiring users to create an account in order to complete an online purchase is a widespread practice in e-commerce. Businesses commonly justify this requirement by reference to operational efficiency, customer convenience, or the development of long-term [...]

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