Contribution on personal data protection (2023-2024)

Contribution of 99 AVOCATS ASSOCIÉS for the International Network of Privacy Law Professionals (INPLP)

"Activity of the personal data supervisory authority of Monaco (CCIN) in 2023/24"

Our article is devoted to the positions of principle of the personal data supervisory authority of Monaco (“CCIN”) formulated in the context of complaints or requests for authorisation to implement data processing in 2023, as well as its recommendations and practical information sheets published in the first quarter of 2024.

Read our article:

• https://inplp.com/latest-news/article/activity-of-the-personal-data-supervisory-authority-of-monaco-ccin-in-202324/
• https://eurocloud.org/news/article/activity-of-the-personal-data-supervisory-authority-of-monaco-ccin-in-202324

INPLP is a not-for-profit international network of qualified professionals providing expert counsel on legal and compliance issues relating to data privacy and associated matters

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ARTICLE CONTENT:

1. Positions of principle of the CCIN formulated in the context of complaints or requests for authorisation to implement personal data processing in 2023

1.1. Principles governing the use of communication tools linked to the professional environment

a) Good practice in electronic messaging when an employee leaves permanently

b) Principles governing the right of access to a private chat and to personal data processed

1.2. Principles governing the personal data processing carried out in the context of the fight against money laundering and the financing of terrorism (AML/CFT)

a) Scope and coverage of the due diligence measures provided for by law

b) Checks on Politically Exposed Persons (PEPs)

c) Origin of the information processed, and the risk assessment profile

d) Retention periods for information processed

2. CCIN recommendations and practical information sheets published in the first quarter of 2024

2.1. Recommendations concerning the publication in the Official Journal (Journal de Monaco) of disciplinary sanctions and disability retirement measures for public sector personnel

a) Disciplinary sanctions published in the Journal de Monaco: right to be forgotten (dereferencing by de-indexation)

b) Retirement on grounds of invalidity published in the Journal de Monaco: right to privacy and restrictions on the processing of health-related data

2.2. New practical information sheets published by the CCIN

a) Practical information sheet on "Cloud computing"

b) Practical information sheet on "The security of processing: a global approach"

c) Practical information sheet on "The criterion of establishment" of the data controller in Monaco

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