ATM Milano has filed criminal complaints and launched a privacy investigation after multiple employees allegedly used onboard surveillance cameras to capture and share sexualized images of female passengers in a WhatsApp group, a scandal that has triggered calls for systemic reform of transport security protocols across Italy.
Why This Matters
• Privacy breach at scale: Transit camera systems meant to protect passengers were allegedly misused to photograph women's bodies without consent.
• Criminal probe underway: Milan prosecutors are moving toward opening a formal investigation following additional victim reports.
• Policy precedent: The case could reshape how Italian transit agencies control access to surveillance footage and discipline staff.
• Immediate action: ATM has reported the incident to local police and intends to file a complaint with Italy's Data Protection Authority (Garante della Privacy).
The Discovery
The alleged misconduct came to light when a female passenger aboard Milan's Tram 15 noticed the driver during a break scrolling through a WhatsApp chat labeled "Ticinese Staff." The group appeared to contain images of female passengers captured from onboard security cameras, accompanied by crude commentary. The woman reported what she saw, and the account quickly reached Carlotta Vagnoli, a prominent activist and writer who published the allegation in her newsletter "Rassegna Stanca." Within hours, several influencers with substantial followings—including former reality TV contestant Carly Tommasini (who appeared on L'Isola dei Famosi, Italy's version of Survivor)—amplified the story on Instagram, forcing a public reckoning.
ATM's statement emphasized the company had "promptly activated with maximum attention" to investigate the episode, verify proper use of corporate tools, and protect both customers and the thousands of employees who work correctly every day. The firm has made clear that respect for people is a foundational and non-negotiable value, promising a "very harsh reaction" and action "in every appropriate venue" for any confirmed irregularities.
What Milan's Mayor Demands
Giuseppe Sala, Milan's mayor, addressed the scandal on the sidelines of an event honoring the memory of Giorgio Ambrosoli. His message was unambiguous: ATM must be both incisive in its analysis and harsh in the measures it takes. "Suppose these are crimes," Sala said. "My instructions to ATM are to be certainly decisive in analysis and tough in the measures to be taken. ATM must shed light but must also intervene, and if those responsible are identified, there should be no interventions that put those who did these things back in a position to harm again."
The mayor's comments reflect broader impatience with workplace misconduct in public services, particularly when it involves the abuse of surveillance technology entrusted to ensure passenger safety.
Legal Landscape and Potential Charges
Codacons, one of Italy's largest consumer protection associations, filed a formal complaint with the Milan Public Prosecutor's Office and the Data Protection Authority. The group is pushing for a full investigation into potential criminal and administrative liability, citing Article 612-ter of the Italian Penal Code, which criminalizes the illicit dissemination of sexually explicit images or videos. Conviction under this statute carries substantial prison sentences and fines.
If prosecutors determine that employees extracted still images from recorded footage and distributed them without consent for prurient purposes, the conduct could also trigger violations of Italy's GDPR implementation, which strictly regulates how personal data—including video surveillance material—may be processed, stored, and shared. The Garante della Privacy has authority to impose administrative fines reaching up to 4% of a company's annual global turnover—which for ATM could potentially mean millions of euros—though enforcement typically focuses on individual accountability within the organization.
What This Means for Residents
For people living in or commuting through Milan, the scandal raises immediate questions about who can see transit camera footage and under what circumstances. Italian and European law mandate that surveillance systems on public transport serve specific, legitimate purposes: preventing vandalism, safeguarding passenger safety, and reconstructing accidents. Access to recordings is supposed to be tightly restricted to authorized personnel, with footage typically retained for a maximum of 72 hours unless needed for active investigations.
The ATM case suggests a breakdown in that chain of custody. Internal audits are now underway to determine whether the images shared in the WhatsApp group were genuine, how employees accessed the footage, and whether any procedural safeguards—such as access logs or dual-authentication protocols—were bypassed or ignored.
Victims who can be identified in the images have the right to pursue civil damages for privacy violations, psychological harm, and reputational injury. Legal experts note that proving harm and establishing a causal link between specific images and individual employees will be key to securing compensation in court.
Broader Context: Harassment on Italian Public Transit
The ATM scandal emerges against a backdrop of persistent sexual harassment on Italian public transport. ISTAT, the national statistics agency, reported in 2018 that 27.9% of sexual harassment incidents experienced by women occur on transit systems. A more recent study from February 2024 found that 29.6% of women aged 14 to 70 had experienced physical harassment on public transport.
A 2025 survey conducted by the University of Milan in collaboration with the regional public transport agency surveyed 3,583 students and university staff. The findings were stark: nearly one in three respondents reported direct experiences of harassment on transit. Among women, 54% cited unsolicited verbal comments and 29% reported inappropriate physical contact.
Italy has no standalone statute criminalizing "upskirting"—the covert photographing or filming beneath clothing—but such conduct can be prosecuted under broader provisions covering sexual harassment, illicit image distribution, and privacy violations. The lack of a specific legal category has sometimes complicated efforts to secure convictions or deter repeat offenders.
How European Transit Agencies Regulate Camera Access
Across the European Union, public transport operators must comply with the General Data Protection Regulation (GDPR), which governs how personal data, including video footage, is collected, stored, and accessed. Transit companies are required to post clear, visible signage informing passengers of camera presence, specify the legal basis for recording (typically "legitimate interest" in safety and security), and limit footage retention to the shortest period necessary.
The Court of Justice of the European Union recently ruled that data captured by body cameras worn by transit inspectors must be disclosed to passengers immediately at the point of collection, reinforcing strict transparency obligations. Violations of GDPR can result in fines reaching millions of euros, depending on the severity and scale of the breach.
ATM's internal procedures are now under scrutiny to determine whether the company met these standards, or whether gaps in oversight allowed employees unsupervised access to sensitive material. The investigation will also examine whether access logs were maintained, how many employees had clearance to view footage, and whether any technical controls—such as watermarking or automatic auditing—were in place.
What Happens Next
ATM's internal inquiry is ongoing, with results expected to inform disciplinary action ranging from suspension to termination. The company has stated it will cooperate fully with law enforcement and the Garante della Privacy. Should the Milan prosecutor's office open a formal investigation, employees identified in the WhatsApp group could face criminal charges, including illicit image distribution and potential violations of workplace conduct statutes.
For passengers, the case serves as a reminder that surveillance is a double-edged tool: effective for deterring crime and resolving disputes, but vulnerable to misuse when institutional safeguards fail. Advocates are calling for stricter access controls, mandatory audits of camera footage retrieval, and clearer sanctions for employees who abuse surveillance privileges.
Milan's experience may set a precedent for how Italian transit operators balance security imperatives with privacy protections, especially as camera systems become more sophisticated and data storage expands. The outcome will be closely watched not only in Milan but across Italy's regional transport networks, where similar systems are in widespread use.
