Sharing the owners' contact list: is it allowed?

Distributing the list of owners' names, addresses, emails and phone numbers is not unrestricted: that data was collected for a specific purpose, managing the condominium and keeping the register required by Article 1130, number 6, of the Italian Civil Code, and cannot be shared with others or used for different purposes without a legal basis. The purpose limitation principle of Regulation (EU) 2016/679 prevents a list gathered to call meetings from becoming a directory to circulate freely.

The concrete case

An owner asks the manager for the full list with everyone's contact details, to organise ahead of a meeting or to reach them. Or the manager, for convenience, sends an email to all with the addresses in the visible recipients field, effectively sharing the address book. In both cases the question arises: how far can that data circulate?

Why the manager holds the data

The manager collects and keeps registry data by legal obligation: keeping the register with owners' particulars, cadastral data and safety information. In respect of this data the condominium is the data controller and the manager acts on its behalf. The purpose is managing the building: calling meetings, allocating expenses, communicating with owners. Any different use must find its own justification.

Can an owner obtain the others' contact details?

An individual owner is entitled to the data needed to exercise their prerogatives, but not to a blanket copy of the address book for personal use. For purposes connected to condominium life, for instance contacting the others about a shared initiative related to management, targeted access may be legitimate, while asking for everyone's emails and mobile numbers for personal purposes unrelated to management goes too far. The manager must assess the purpose and share only proportionate data.

• Data to exercise condominium rights (challenge, check quorum): targeted access allowed
• Full copy of emails and phones for personal use: generally not owed
• Sharing with third parties outside the condominium: forbidden without a legal basis
• Commercial or promotional use of contacts: always excluded

The mistake of visible-copy emails

Sending a communication to all owners with the addresses in the visible recipients field means disclosing everyone's address book to each of them. It is one of the most frequent mishaps and amounts to unnecessary data disclosure. The practical rule is to use the blind copy field, so each recipient sees only their own address, or to send individual messages. Better still is a dedicated channel where each person receives the communication without seeing the others.

When sharing data is lawful

Some disclosures are provided for by law or meet a legitimate interest. The manager shares with suppliers the data needed for the services, with the Revenue Agency the data for tax compliance, and with the condominium's creditors, who may request the data of defaulting owners to act on a subsidiary basis. Outside these typical cases, dissemination or disclosure must be justified and limited to the strict minimum.

Good practices

• Give owners the data processing information notice
• Communicate via blind copy or individual sends, never plain address books
• Answer access requests weighing purpose and proportionality
• Do not hand contact details to people outside condominium management

The manager's role

The manager is the concrete guarantor of the proper flow of data. They must organise communication so that no owner sees the others' contact details without need, keep a record of access requests and replies, and adopt adequate measures to protect the archive. An orderly approach reduces complaints and demonstrates compliance in case of dispute.

A tool that sends personalised communications without exposing others' addresses and keeps the register protected greatly simplifies the work. With AmministraPro the manager contacts owners individually, handles access requests and keeps the register up to date in line with the purposes: the features are on the /funzioni page and the plans on the /prezzi page.