Practical guide
Managing owners' contact details: email and PEC
A communication reaches its destination only if the contact detail is correct and up to date. In condominium management contacts are no detail: they are part of the condominium register the manager must keep under Article 1130, number 6, of the Italian Civil Code, and their accuracy directly affects the validity of meeting notices and the traceability of reminders. This guide explains how to collect owners' email and PEC, how to distinguish the correct recipient between owner and tenant, how to keep data aligned with changes of ownership and how to handle it in line with Regulation (EU) 2016/679, avoiding the two opposite extremes of an address book stuck in the past and an excessive collection of data.
Contacts are part of the condominium register
Article 1130, number 6, of the Italian Civil Code requires the manager to keep the condominium register with the personal details of individual owners and holders of real and enjoyment rights, plus the cadastral data of each unit. Contacts, though not always expressly mentioned, are the operational tool that makes this register usable for communications. Each owner is required to communicate in writing any change to the data concerning them.
Treating contacts as an integral part of the register, and not as a separate address book kept elsewhere, avoids misalignments: when a unit's ownership changes or an owner reports a new address, the update must be reflected in a single point from which all communications draw.
Distinguishing the recipient: owner or tenant
Not all communications go to the same person. Decisions affecting ownership, extraordinary expenses, notices to resolve major works, concern the owner; some communications tied to ordinary management and daily use may instead concern the tenant. An address book that does not distinguish roles sends the notice to the wrong person, with the risk, for meeting notices, of defects that make the resolution voidable.
It is therefore best to record for each unit both the owner and any tenant or usufructuary, with their respective contacts, and to associate the correct recipient with each type of communication. This is especially useful in condominiums with many rented units, where the overlap of roles is frequent.
Collecting email and PEC in an orderly way
The best moment to collect contacts is the meeting, where each owner can be asked to confirm or update their data and to indicate whether they have a PEC address and intend to use it for communications. The owner's formal communication of the PEC is what allows the manager to use it as a suitable channel under Article 66 of the implementing provisions of the Italian Civil Code.
It helps to record, alongside each contact, the owner's preferred channel: PEC, ordinary email or paper post. This way the same notice can be routed automatically through the right channel for each one, without deciding manually case by case and without using PEC towards someone who has not provided it.
- Per unit: owner and any tenant or usufructuary
- Per person: email, PEC if provided, postal address
- Preferred channel indicated by the owner for communications
- Date of the last update and source of the change
Updating data at changes of ownership
Contacts age quickly: changes of ownership, successions, new lease contracts, relocations. If the register does not follow these changes, communications end up with someone who is no longer the recipient and reminders reach the wrong person. The manager must take in owners' written communications and, when they become aware, update the data; it is good practice to check the register periodically, typically at the annual meeting.
When a unit changes owner, the update concerns not only the contact but the whole position: who is liable for expenses, who must be summoned, to whom notices should be addressed. Keeping contacts and accounting position linked prevents a communication that is correct in content from reaching the wrong owner.
Privacy and data minimisation
Contacts are personal data and must be handled in line with Regulation (EU) 2016/679, that is, collected for the sole purpose of condominium management, stored securely and not disclosed to unauthorised third parties. In practice this means not exposing other owners' addresses in collective sends, not disclosing contacts to those without title and not collecting more data than necessary.
Management software helps respect these principles by keeping contacts linked to the register, updatable in a single point and usable to send each owner only what concerns them, through the right channel. AmministraPro lets you manage contacts, roles and preferred channel in the owner's file and send communications directly from there: the features are described on the /funzioni page and the plans on the /prezzi page.
Frequently asked questions
Can the manager use an owner's PEC without their consent?
PEC can be used as a suitable channel when the owner has formally provided their address, typically in writing. Without this communication the manager cannot assume they may use it and must resort to the other means under Article 66 of the implementing provisions of the Italian Civil Code, such as registered mail. The owner's communication of the address is the precondition.
Are contacts part of the mandatory condominium register?
Article 1130, number 6, of the Italian Civil Code requires the register with owners' and rights-holders' personal details and cadastral data. Contacts are the operational tool that makes the register usable for communications: keeping them linked to the personal data, and not in a separate address book, is the correct practice to avoid misalignments.
Whom should I send the communication to, the owner or the tenant?
It depends on the subject. Decisions affecting ownership and extraordinary expenses concern the owner, who must be summoned for the relevant resolutions; some communications on ordinary management and daily use may concern the tenant. Recording both roles for each unit, with their respective contacts, lets you address each notice to the correct person.
How often should the contact list be updated?
There is no fixed frequency, but it is good practice to check the register at least at the annual meeting and whenever a change comes to light, such as a change of ownership or a new lease. The manager takes in owners' written communications, who are required to report changes to their data, and updates the contacts accordingly.
Can I share one owner's contacts with another owner?
In general no, unless there is a basis that justifies it. Contacts are personal data processed for the purpose of condominium management and must not be disclosed to unauthorised third parties under Regulation (EU) 2016/679. In collective communications others' addresses must not be visible, and requests to access others' data must be assessed carefully case by case.
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