Email and PEC in Condominiums: Privacy Rules

Sending communications to the condominium by email or certified email (PEC) is practical, but it is also one of the activities where the most privacy mistakes are made. The classic error is placing all owners' addresses in the To or Cc field, making them visible to everyone: this is an unauthorized disclosure of personal data. The rule is to use the Bcc field for group sends, send only the necessary data and choose the channel appropriate to the nature of the communication. These are simple but decisive steps.

The Bcc field for group sends

When writing to several owners with a single email, the addresses must go in blind carbon copy, the Bcc field. This way each recipient receives the message without seeing the others' addresses. Placing the same addresses in the To field or in normal carbon copy exposes them to everyone: an email address is personal data, and disclosing it to unauthorized parties is unlawful processing. It is a trivial but frequent mistake, often at the root of complaints to the Garante.

Minimizing data in the content

Beyond the addresses, the content matters too. A group communication must not reveal information concerning an individual, such as an owner's arrears position or data revealing personal conditions. If a payment reminder is needed, or something concerning a single person, the message must be addressed only to that person, not to the whole condominium. The minimization principle requires processing, and therefore communicating, only the data necessary for the purpose.

• Group sends always in Bcc, never in To or Cc
• Communications about an individual addressed only to that person
• No arrears or personal-condition data in group messages
• Attachments with third-party data only to those entitled

When PEC is needed

Certified email gives legal value to the transmission, with proof of sending and delivery. In condominiums, PEC is useful for communications that require legal certainty, for example certain meeting notices, if the owner has indicated PEC as a contact, or acts requiring a certain date. Article 66 of the implementing provisions of the Italian Civil Code recognizes certified email among the means of calling a meeting. Even with PEC the minimization rules apply: one PEC per recipient avoids exposing others' addresses and positions.

Ordinary email: convenient but limited

Ordinary email remains the most used channel for informal communications, but it is less secure and has no evidential value. It must be used consciously: care with Bcc, caution over attachments containing third-party data, and no transmission of credentials or sensitive data without protection. For confidential documents it is preferable to provide a restricted area from which the owner downloads them after authenticating, rather than attaching them to an email that could be forwarded or intercepted.

Consent, legal basis and contact details

Using owners' contact details for management communications generally does not require consent, because it falls within the manager's duties and the management of the condominium. Consent is instead needed for further, non-necessary purposes. Contact details must be collected in the condominium register provided for by Article 1130 of the Italian Civil Code, kept updated and used only for the purposes stated in the privacy notice. Changing purpose without informing the data subject is non-compliant processing.

Retention and archiving

Communications and PEC receipts must be kept for the time needed to document the management activity and, for PEC, to prove that transmission occurred. A disorganized mailbox, with years of messages containing many condominiums' data, is itself a risk. It is better to archive communications by condominium and by matter, so they can be retrieved and what is no longer needed can be deleted. Storage limitation applies to email too.

Communicating well with the right tools

Management software that sends communications to owners automatically handles recipient separation and archiving by condominium, reducing the risk of manual errors such as a forgotten Bcc. AmministraPro integrates sending communications and email and managing PEC with the condominium archive, so each message stays linked to the right matter. The communication features are described on the /funzioni page and the plans that include them on the /prezzi page, so you can write to owners while respecting their privacy.