L’art. 615 bis del Codice Penale punisce con la reclusione da sei mesi a quattro anni “chiunque, mediante l’uso di strumenti di ripresa visiva o sonora, si procura indebitamente notizie o immagini attinenti alla vita privata svolgentesi nei luoghi indicati nell’articolo 614 c.p.”.
Integra, dunque, il reato di inferenza illecita nella vita privata altrui la condotta di chi registra o riprende un soggetto nei luoghi elencati all’art. 614 c.p. ovvero nell’abitazione altrui o nella privata dimora o nelle pertinenze di essi.
A parere della Suprema Corte di Cassazione per privata di dimora si intende “qualunque luogo destinato alla permanente o transitoria esplicazione della vita privata o delle attività lavorative. Rientrano dunque nel concetto di privata dimora tutti quei luoghi che, oltre all’abitazione, assolvono alla funzione di proteggere la vita privata e che siano perciò destinati al riposo, all’alimentazione, alle occupazioni professionali e all’attività di svago” (Cass. Penale, n. 41646/2013).
In una recente sentenza la Corte ha affermato, in particolare, che anche il luogo di lavoro può assumere le caratteristiche del luogo di “privata dimora”, a condizione che “il rapporto tra la persona offesa e la res non sia occasionale e laddove l’ingresso sia riservato al personale per lo svolgimento anche di manifestazioni della vita quotidiana” (Cass. Penale, n. 40289/2018).
Non è, pertanto, possibile escludere a priori che il luogo nel quale avvenga la registrazione della conversazione possa considerarsi “privata dimora”; conseguentemente non è possibile escludere che la condotta in esame possa integrare gli estremi del reato di cui all’art. 615 bis c.p.
Alla luce di quanto esposto, risulta opportuno evitare le condotte in commento, non potendo escludere la configurabilità del reato sopra citato.
A ciò si aggiunga che si porrebbero in ogni caso i temi della liceità degli strumenti di controllo dei lavoratori (si può escludere la liceità di registrazioni occulte di conversazioni tra soggetti ignari della registrazione stessa) ed i temi di tutela della privacy e della riservatezza, e relative sanzioni.
Le registrazioni, in astratto, potrebbero essere ritenute lecite solo qualora destinate a costituire un circoscritto e ben delimitato strumento di difesa da fare valere in giudizio.
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