WhatsApp chat run by the manager: the responsibilities

Many managers use WhatsApp to communicate with owners: quick notices, reminders, a photo of a fault. But when it is the manager, in carrying out their role, who runs the chat, the picture changes compared with a group started spontaneously among neighbours. The household exemption does not apply and the processing becomes professional, with precise responsibilities on the manager as controller. Let us see what this involves and how to use these channels without exposure.

Why the household exemption does not apply to the manager

The GDPR excludes from its scope processing carried out by a natural person for purely personal or household activities. A group started among neighbours to exchange a few words may fall within it. But when the manager uses the chat to perform their professional role, that is, to run the condominium, the processing is no longer personal: it is connected to a professional activity and the ordinary obligations of the Regulation fall on the manager. The difference is not formal; it changes the liability regime.

The manager as controller

By managing communication on the condominium's behalf, the manager acts as data controller in the capacity of legal representative. They must therefore identify a legitimate purpose, an adequate legal basis, inform owners about the processing and adopt proportionate security measures. They cannot simply create a group and add everyone: every choice about the channel used and the data processed must be justifiable under the accountability principle.

The problem of visible numbers

The structural flaw of a messaging group is that it makes each participant's phone number visible to all. Adding owners to a group means disclosing their contact details to the others, a processing that, without an adequate legal basis, is problematic. For notices that require no interaction, a distribution list in which recipients cannot see each other is preferable to an open group, because it avoids the mutual disclosure of numbers.

• Obtain consent before adding an owner to an open group.
• Prefer distribution lists, where numbers are not visible to all.
• Let those who do not wish to take part receive notices by other means.
• Limit the channel to communications relating to condominium life.
• Do not process excessive data in the chat, such as named defaults or sensitive data.

What never to entrust to the chat

The chat is fine for informal notices, but it does not replace communications with legal value. The convening of the owners' meeting follows precise forms and deadlines, set by Article 66 of the implementing provisions of the Italian Civil Code, and cannot validly be entrusted to a message. Likewise, payment reminders with legal effects and official communications require traceable channels. Confusing the informal channel with the formal one exposes the manager to disputes over the validity of acts.

The missing control over data

A limit of widely used messaging services is that the manager has no control over where and how data is kept and processed by the platform provider. This makes it hard to ensure full GDPR compliance, particularly on retention times and security. For communications that must remain documented and confidential, a dedicated management tool offers guarantees that a general chat cannot, starting with the profiling of access.

Practical rules for the manager

A few precautions substantially reduce the risk. Use the chat only for non-confidential, non-binding notices, avoid disclosing individual owners' data, ask for consent for open groups and always offer an alternative to those who prefer not to use messaging. Formal communications and confidential data must be handled on traceable, secure channels. In this way the convenience of the chat remains an advantage without becoming a source of liability.

To separate informal notices from official, traceable and confidential communications, a dedicated channel is safer than a general chat: AmministraPro manages communications, the owner portal and notifications with profiled access. The features are described on the features page and the plans on the pricing page.