INFORMATION ON THE PROCESSING OF PERSONAL DATA
In accordance with Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data (hereinafter, for brevity, ‘Regulation’ or ‘EU REG’ or ‘GDPR’) and subsequent amendments, Opera Universitaria di Trento aims to contribute to the achievement of the general strategic objectives of the institution; in accordance with and because of the effects of Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of EU Regulation 679/2016, Opera Universitaria di Trento provides you with the following information regarding the processing of your personal data, including those communicated by you on the occasion of services rendered through specific sections of the site, in order to follow up on specific requests and the resulting services.
Purpose of the processing for which the personal data are intended and legal basis of the processing
The collection and processing of your personal data are carried out:
- in order to implement the objectives of Opera Universitaria di Trento, stated by its founding law, Provincial Law no. 9 of 24 May 1991, for the purpose of providing the services stated by said law. In these cases, the legal basis of the data processing is the performance of contractual obligations by Opera Universitaria di Trento;
- for the proper execution of obligations imposed by laws, regulations or EU legislation, as well as to comply with provisions issued by public authorities legitimated to do so or by supervisory and control bodies to which Opera Universitaria di Trento is subject. In these cases, the legal basis for the data processing is the fulfillment of a legal obligation in accordance with art. 6.1, letter c) of the GDPR);
- subject to your explicit consent, for purposes linked to the provision of services stated by Provincial Law no. 9 of 24 May 1991, such as, for instance, service quality surveys or statistical surveys. In these cases, the legal basis of the data processing consists in the expression of explicit consent in accordance with Art. 6.1, letter a) of EU REG).
Nature of data provision and consequences of failure to provide data
Refusal to provide personal data or failure to provide consent to their processing shall make it impossible for Opera Universitaria di Trento to provide the requested services and to implement the objectives set out in point 1, letters a) and b) of this information notice.
The provision of data for the purposes set out in point 1, letter c) of this information notice is, on the other hand, optional and the data provider is therefore free to give or refuse consent to the provision of data. Even after consent has been given, the data provider is free to revoke it at any time.
Modalities of data processing
The processing of your personal data will be based on the principles of lawfulness, correctness and transparency, protecting your privacy as well as that of your family members, in compliance with the principles set forth in Article 5 of the EU REGULATION. The data may be processed manually, using paper documents and also with the aid of electronic or automated means; The data are collected and processed at the headquarters of Opera Universitaria di Trento, in special documental archives/servers.
Your personal data are processed using suitable technical and organizational security measures in accordance with art. 32 of the EU REG., so as to ensure a level of security appropriate to the risk, minimizing the risks of destruction or loss, unauthorized access or processing not in accordance with the purposes of collection.
Your personal data are not subject to automated decision-making nor profiling.
Special categories of personal data (‘sensitive data’)
According to Art. 9 paragraph 1 of the EU-REG, ‘sensitive data’ are ‘personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union memberships, as well as genetic data, biometric data capable of unequivocally identifying a natural person, data concerning a person's health or sexual life or sexual orientation’.
In order to achieve its objectives, Opera Universitaria di Trento may process your sensitive data, such as, for example, data relating to your health status or that of your family members, as well as your membership to a trade union.
The processing of your sensitive data will be carried out with all the guarantees and in compliance with the limits provided for by the EU REGULATION. In particular, only data strictly pertinent to the aforementioned obligations, tasks or purposes that cannot be fulfilled or achieved through the processing of anonymous data or personal data of a different nature will be processed.
The processing of sensitive data may take place if the data provider has given their explicit consent, or in accordance with Art. 9 paragraph 2) letter d) of the EU REG., even without the consent of the data provider when the processing is carried out during its legitimate activities and with appropriate guarantees by an association or other non-profit body pursuing trade union purposes, provided that the processing relates solely to members, former members or persons who have regular contact with the association or body because of the body’s objectives and that the personal data are not disclosed without the consent of the data provider.
In accordance with art. 9, paragraph 2, letter h) of the EU REG., moreover, sensitive data may be processed without the data provider’s consent where the processing is necessary, inter alia, for the management of health or social systems and services on the basis of Italian or European Union law.
Disclosure of data
Your personal data shall not be disclosed.
For the purposes outlined in section 1) of this privacy notice, Opera Universitaria di Trento may need to disclose your personal data to trusted external parties, specifically:
a) To professional bodies, including their territorial divisions, and third-party companies, as necessary, for the performance of institutional services and tasks;
b) To banking institutions for banking services and payments, companies that manage digital postal services, document archiving and storage companies, and other third-party providers of outsourced ancillary services;
c) To healthcare facilities and specialist physicians with whom a contractual agreement is in place;
d) To medical consultants, healthcare personnel, and legal advisors of Opera Universitaria di Trento;
e) To insurance or reinsurance companies or directly to third-party liable entities in the event of a recourse action.
These entities, depending on the case, will process the data as independent "Data Controllers" or as "Data Processors" duly appointed pursuant to contractual agreements in accordance with Article 28 of the EU General Data Protection Regulation (GDPR).
Your personal data will not be transferred to non-EU countries or international organizations. However, in specific instances, upon the explicit request of the data subject and in compliance with the provisions of the GDPR, your data may be transferred outside the national territory to execute payments through foreign banks.
Personal Data Retention Period
Your personal data will be retained for the duration of the contractual relationship and thereafter for the period necessary to comply with all applicable legal obligations (e.g., fiscal obligations) and/or administrative tasks related to or derived from the contractual relationship.
Identity and Contact Details of the Data Controller and the Data Protection Officer (DPO)
The Data Controller is Opera Universitaria di Trento, with its registered office in Trento, via della Malpensada n. 82/A.
The Data Controller can be contacted via email at: operauniversitaria@pec.operauni.tn.it or by phone at +39 0461.217411, fax +39 0461.217444.
The updated list of Data Processors, if requested, is available at the operational headquarters of Opera Universitaria di Trento.
The Data Protection Contact Person, whom you may contact to exercise your rights under the GDPR listed in section 8 below, can be reached at: Opera Universitaria di Trento, Via della Malpensada n. 82/A, 38123 Trento
Fax: + 39 0461.217444 - PEC: operauniversitaria@pec.operauni.tn.it - Email: referenteprivacy@operauni.tn.it - Phone: +39 0461.217411.
It is also confirmed that a Data Protection Officer (DPO) has been appointed and can be contacted via email at: dpo@operauni.tn.it.
Rights of the Data Subject
At any time, where applicable, and pursuant to Article 7 of Legislative Decree 196/2003 and Articles 15 to 22 of the GDPR, you have the right to:
- Request confirmation of whether or not personal data concerning you is being processed;
- Obtain information regarding the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data has been or will be disclosed, and, where possible, the retention period;
- Request the rectification or erasure of data;
- Request the restriction of processing;
- (Where applicable) Obtain data portability, i.e., receive your personal data from a Data Controller in a structured, commonly used, and machine-readable format, and transmit it to another Data Controller without hindrance;
- Object to processing at any time, including for purposes of direct marketing;
- Object to automated individual decision-making, including profiling;
- Request access to your personal data and request the rectification or erasure of such data, or request the restriction of processing, or object to processing, as well as the right to data portability;
- Withdraw consent at any time, without affecting the lawfulness of the processing based on the consent provided before the withdrawal;
- Lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), located in Rome, Piazza Venezia n. 11, official website: garanteprivacy.it
The exercise of your rights is not subject to any formal requirements and is free of charge.
Data Controller
The Data Controller is Opera Universitaria - tel. +39 0461.217411 - via della Malpensada, 82/A - 38123 Trento.
Data Protection Officer (DPO)
The Data Protection Officer is Attorney Elisa Lagni - e-mail: dpo@operauni.tn.it