Under the lens of the Guarantor for privacy, various local authorities are showing a growing interest in initiatives based on reward-type solutions that make use of scoring mechanisms associated with "virtuous" behavior of the citizen in various sectors (environment, taxation, culture, mobility, sport).
The investigations launched by the Authority, both ex officio and upon notification, concern a series of projects promoted by public and private entities, which envisage the assignment of scores also with regard to data collections provided "voluntarily" by the interested parties.
The Authority's interventions were made necessary due to the risks associated with profiling mechanisms which involve a sort of "citizenship chart" and which could have negative legal consequences on the rights and freedoms of the data subjects, including the most vulnerable subjects. The Authority reserves the right to adopt any measures resulting from the results of the investigations in progress.
An investigation that has just started concerns the "Pollicino Project", an experimental statistical survey - promoted by the Foundation for Sustainable Development, the Ministry of Ecological Transition and the Ministry of Sustainable Infrastructure and Mobility - through which citizens are invited to share their data (apparently "anonymously"), to allow an analysis of mobility. At the end of the survey, the citizen is expected to receive prizes offered by the private partners of the Project. The survey will be the first to concern the Municipality of Bologna. The Authority therefore requested clarifications from the Foundation, the Municipality of Bologna and the Ministries concerned in order to know, in particular, the role of the public and private subjects involved, the legal basis of the processing, the operating methods of the app system and the processing connected to it.
Another investigation recently launched on similar issues concerned the "smart citizen wallet" initiative of the Municipality of Bologna, within which citizens can voluntarily join a system that allows them to accumulate "credits" for all inside your "walletC (wallet), to be spent by accessing a series of rewards / incentives made available by the Municipality and accredited partners.
Previously, the Guarantor dealt with a project initiated by the Municipality of Fidenza, which had introduced, with its own Regulations, the so-called "assignee card" of public residential housing. Also in this case, there is a scoring mechanism associated with the behavior of the assignees of the accommodation, through a scoring system aimed at recognizing benefits and penalties, including the termination and / or forfeiture of the lease, with possible prejudicial consequences. for categories of vulnerable subjects.
In recalling all local authorities to carefully evaluate any future adoption of "social scoring" projects or derivatives thereof, the Guarantor reiterates the need for these initiatives to always and in any case be anticipated by timely impact assessments and respect the fundamental principles of the EU regulation.