Alessandro AleddaInsider Threat and Risk

INTRA/PS/PS010Line management records of personal circumstances

Records of a worker’s personal or family circumstances kept by the people who manage them, including those held outside any system the program runs: a manager’s notebook, a shared drive, a private note.

Pillar
PS  |  Personnel security
Sources cited
1
Added
30 AUGUST 2026
Updated
30 AUGUST 2026
ControlJurisdictionSourceWhat it establishesPrerequisite or recommendation
PS010/ITMandatoryItalyProvvedimento n. 107, Amazon Italia LogisticaGarante per la protezione dei dati personali · read 16 Aug 2026That records of illness, union activity, and family circumstances kept by managers had no lawful basis, and attract the stricter regime.Notes kept by managers about a worker’s circumstances are processing like any other: outside a declared purpose and a lawful ground they have neither.