TL;DR for the DPO
Decision 797 of 30 December 2025 sets the Garante's H1 2026 inspection areas. Inspections involve the Finance Police tech-fraud unit, so they can have criminal implications. Notice can be short.
Areas in focus
- Data breaches in public databases, abusive access and resale of information
- Large-scale processing and special categories
- Security measures and the ability to demonstrate what was done (accountability)
The lesson from recent decisions
After Intesa Sanpaolo (EUR 31.8M) the standard is clear: not suffering an attack is not enough, you must be able to PROVE you did the right things. Documented self-assessment changes the sanctioning outcome.
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