Practical guide
Privacy at the meeting: recordings, minutes and proxies
The owners' meeting is the moment when the most personal data is processed together: names of attendees, participation shares, arrears situations, proxies, opinions expressed and sometimes sensitive matters concerning individual owners. The minutes, required by Article 1136 of the Italian Civil Code and Article 66 of the implementing provisions, must record the decisions without becoming a container of excessive personal information. Audio or video recordings, requests for confidentiality and the presence of outsiders must be handled with clear criteria, to respect both the meeting rules and the GDPR.
What the minutes may contain
The minutes must record the elements needed to document the validity and content of the resolution: constitution of the meeting, attendees and their thousandths (millesimi), proxies, topics discussed, voting results and decisions taken. This data is legitimate because it serves the very function of the minutes and any challenge within the time limits set by law.
It is instead best to avoid including irrelevant personal information, such as details about a person's health, family or judicial matters, unless strictly necessary for the decision. The minimisation principle requires noting only what is needed, with restrained wording that does not expose the attendees' private sphere more than necessary.
- Yes to attendees, thousandths, proxies, votes and resolutions
- Yes to mentioning arrears when they affect management
- No to details on health, family or judicial matters that are irrelevant
- No to personal judgements or harmful remarks minuted without need
Audio and video recordings: when they are allowed
Recording the meeting, in audio or video, involves processing the data of all attendees. There is no absolute ban, but a recording cannot be imposed unilaterally or kept without the attendees' knowledge. The correct path is to inform the meeting and obtain agreement on the recording, defining its purpose and destination.
A person recording for personal use, to remember what was discussed, may do so, but cannot share the recording with unrelated third parties or publish it. Disseminating the images or voices of attendees beyond the entitled audience is a further processing that requires its own basis and, absent one, is unlawful.
Proxies and the presence of outsiders
Proxies collect data of both the grantor and the proxy holder and must be kept as meeting documentation, with the same safeguards as other condominium documents. They must not be left unattended or shown to anyone without the right to consult them.
The presence at the meeting of people unrelated to the condominium, such as technicians, consultants or companions, must be assessed carefully. When data concerning individual owners is discussed, the presence of unauthorised outsiders can make the communication problematic. It is good practice to limit outsiders' participation to the relevant moments only and to inform the meeting of their presence.
Managing the meeting and documents in an orderly way
Correct handling of meeting data is built on order: minutes drafted with measure, proxies stored securely, distribution of the minutes to entitled persons only, and logged access. Distributing the minutes through private channels, rather than posting them in common spaces, reduces the risk of undue disclosure.
A platform such as AmministraPro lets you prepare notices, draft and archive minutes, manage proxies and share documents through personal access for each owner. The features are described on the /funzioni page and the plans on the /prezzi page.
Frequently asked questions
Can I record the condominium meeting?
There is no absolute ban, but a recording processes the data of all attendees and cannot be imposed or kept without their knowledge. The correct path is to inform the meeting and obtain agreement, defining purpose and destination. A person recording for personal use still cannot share the recording with third parties.
Can the minutes contain the names of defaulting owners?
Yes, when arrears affect management and cost allocation, their mention in the minutes is legitimate because it documents the accounting situation and the decisions taken. Irrelevant personal details, such as information on health or private matters, should instead be avoided, in line with the minimisation principle.
How should proxies be kept?
Proxies contain data of the grantor and the proxy holder and must be kept as meeting documentation, with the same safeguards as other condominium documents. They must not be left unattended or shown to anyone without the right to consult them, and must be accessible only to authorised persons.
Can people unrelated to the condominium attend the meeting?
The presence of technicians, consultants or companions must be assessed case by case. When data of individual owners is discussed, the presence of unauthorised outsiders can make the communication problematic. It is good practice to limit their participation to the relevant moments and to inform the meeting of their presence.
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