Stefano Gazzella : 22 September 2025 07:17
Managing employee email inboxes is often overlooked by organizations, despite the widespread use of email and its significant impact on privacy and security . Despite being a work tool, an individual email inbox (and therefore, assigned to a single operator) is considered the employee’s digital home and, therefore, requires reasonable protection to safeguard the rights, fundamental freedoms, and dignity of the data subjects involved in the exchange of communications (both the account holder and third parties).
This complexity, recognized not only by case law but also by supervisory authorities with regard to applicable data protection legislation, therefore requires particular attention in coordinating technical configuration aspects with organizational measures such as instructions, policies, and usage guidelines regarding aliases, groups, distribution lists, function inboxes, and individual inboxes.
In practical terms, the adoption of an internal policy to govern the use of email represents the outcome of a thorough process that must take into account technical and regulatory requirements to ensure system security, including organizational continuity, and the protection of the personal data of operators and other individuals involved in email flows.
This is why giving in to the temptation to resort to one-size-fits-all solutions or wild copy-and-paste approaches is never a good choice. Much less will it provide evidence of any reasoning, nor does it contribute to the organization’s ability to comply with personal data protection regulations. Rather, it merely reflects the reasoning of someone other than the organization adopting it. The result is a series of rules disconnected from the context, often ineffective, contradictory, and difficult for operators to understand.
Planning the drafting and adoption of a specification is therefore the main organizational measure for mitigating both regulatory compliance and security risks.
The guidelines for the design of a regulation for the use of electronic mail have been provided by the Privacy Guarantor since 2007 , identifying the correct method of drafting and formal dissemination in accordance with the employment law indications and the essential contents to be provided and the fundamental contents.
Regarding the form , this must consist of a series of specific instructions and clear language. This essentially means providing a DO/DON’T structure indicating behaviors to be adopted and prohibited . To be effective, they must then be disseminated either to individual workers or otherwise through publication (on noticeboards or intranet, as provided for in Article 7 of the Workers’ Statute). However, to remain effective over time, they must be updated and reviewed periodically, especially as the technological and organizational context changes.
As for the contents , a useful checklist to adopt is the following:
All of this, of course, is necessary but not sufficient to properly regulate behaviors so that they comply with regulations, good safety practices, and any additional instructions received. What is needed is a concrete and current reference to the operations actually performed, without generic formulas, and, above all, a clear understanding of the regulations by the recipients. This may also include targeted training to address any concerns, objections, or suggestions for improvement from workers.
Regulating email management isn’t just helpful, it’s essential. Which is why you need to get your head around it first, so you don’t regret it later.
Otherwise, when all those downstream problems that could have been avoided upstream emerge, we will find ourselves facing a series of operational, strategic, and financial costs.
Preventing that sigh if only I had thought of it before , transversal in both legal and security aspects.
Stefano Gazzella