INFORMATION ON THE PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data (hereinafter, for brevity, the “Regulation” or “EU REG.“) and subsequent amendments.Opera Universitaria di Trento aims to contribute to the achievement of the institution’s general strategic objectives; Pursuant to and for the purposes of Article 13 of Legislative Decree 196/2003 and Articles 13 and 14 of European Regulation 679/2016, Opera Universitaria di Trento provides you with the following information regarding the processing of your personal data, including data you provide when using services provided through specific sections of the website, to fulfill your specific requests and provide the resulting services.

Purpose of the processing for which personal data is intended and legal basis for processing

Your personal data is collected and processed:

• To implement the purposes of Opera Universitaria di Trento, as set forth in its founding law, Provincial Law No. 9 of 24 May 1991, for the purpose of providing the services specified in that law. In such cases, the legal basis for processing is the performance of contractual obligations by Opera Universitaria di Trento.

• for the correct execution of obligations established by laws, regulations, or EU legislation, as well as to comply with provisions issued by public authorities authorized to do so or by supervisory and control bodies to which Opera Universitaria di Trento is subject. In such cases, the legal basis for processing is the fulfillment of a legal obligation pursuant to Article 6.1, letter c) of the GDPR).

• • subject to your explicit consent, for purposes ancillary to the provision of the services provided for by Provincial Law No. 9 of May 24, 1991, such as, for example, for surveys on the quality of services or statistical surveys. In such cases, the legal basis for processing consists of the explicit consent pursuant to Article 6.1, letter a) of the EU Regulation.

Nature of the provision of data and consequences of failure to provide data

Refusal to provide personal data or failure to consent to their processing will make it impossible for Opera Universitaria di Trento to provide the requested services and implement the purposes referred to in point 1, letters a) and b) of this privacy policy.

The provision of data for the purposes referred to in point 1, letter c) of this privacy policy is optional, and the data subject is therefore free to give or deny consent. Even after consent has been given, the data subject is free to withdraw it at any time.

Data Processing Methods

The processing of your personal data will be based on the principles of lawfulness, fairness, and transparency, protecting your privacy and that of your family members, in compliance with the principles set forth in Article 5 of the EU Regulation. Processing may be carried out manually, using paper documents, and also with the aid of electronic or automated means.

The data is collected and processed at the headquarters of Opera Universitaria di Trento, in dedicated document archives/servers.

Your personal data is processed using appropriate technical and organizational security measures pursuant to Article 32 of the EU Regulation, in order to guarantee a level of security appropriate to the risk, minimizing the risk of destruction or loss, unauthorized access, or processing inconsistent with the purposes for which it was collected.

Your personal data is not subject to automated decision-making or profiling.

Special categories of personal data (“sensitive data”)

Pursuant to Article 9, paragraph 1 of the EU Regulation, “sensitive data” means “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.”

To achieve its purposes, Opera Universitaria di Trento may process your sensitive data, such as data relating to your health or that of your family members, as well as trade union membership.

The processing of your sensitive data will be carried out with all guarantees and in compliance with the limits set by the EU Regulation. Specifically, the processing will only concern data strictly relevant to the aforementioned obligations, tasks, or purposes, which cannot be fulfilled or achieved through the processing of anonymous data or personal data of a different nature.

The processing of sensitive data may take place if the data subject has given his or her explicit consent, or pursuant to Art. 9, paragraph 2, letter d) of the EU Regulation. EU, even without the data subject’s consent when the processing is carried out, in the context of its legitimate activities and with adequate safeguards, by an association or other non-profit organization pursuing trade union objectives, provided that the processing concerns only members, former members, or persons who have regular contact with the association or organization for its purposes and that the personal data are not disclosed outside the organization without the data subject’s consent.

Furthermore, pursuant to Article 9, paragraph 2, letter h) of the EU Regulation, sensitive data may be processed without consent even where the processing is necessary, inter alia, for the management of health or social systems and services pursuant to Italian or European Union law.

Data communication

Your personal data will not be disclosed.
To carry out the purposes set out in point 1) of this privacy policy, Opera Universitaria di Trento may need to disclose your personal data to trusted external parties, specifically:
a) professional bodies, including their local branches, as well as third-party companies, where necessary, limited to the performance of institutional services and tasks;
b) credit institutions for banking and payment services, companies that manage electronic postal services, document archiving and storage companies, and other outsourced providers of related services;
c) healthcare facilities and medical specialists with whom a contractual relationship exists;
d) medical consultants, healthcare personnel, and legal advisors of Opera Universitaria di Trento;
e) insurance or reinsurance companies, or directly to third parties responsible in the event of a claim for compensation.

The aforementioned entities, as applicable, will process the data as independent data controllers or “data processors” duly appointed pursuant to contractual agreements drawn up in accordance with the provisions of Article 28 of the EU Regulation.
Your personal data will not be transferred to a third country outside the EU or to international organizations. Occasionally, at the data subject’s explicit request, in compliance with the provisions of the EU Regulation, they may also be transferred outside of Italy to process payments for services to foreign banks.

Period of personal data retention

Your personal data will be retained for the entire duration of the contractual obligation and even after its termination for the time necessary to fulfill all applicable legal obligations (e.g., tax-related) and/or administrative obligations related to or arising from the contractual obligation itself.

Identity and contact details of the Data Controller and the Data Protection Officer (DPO)

The data controller is Opera Universitaria di Trento, with registered office in Trento, Via della Malpensada 82/A.

The Data Controller can be contacted at the email address: operauniversitaria@pec.operauni.tn.it or by telephone at +39 0461 217411 or fax at +39 0461 217444.

The updated list of data processors, upon request, is available at the headquarters of Opera Universitaria di Trento.

The Privacy Officer, whom you may contact to exercise the rights provided for by the EU Regulation listed in point 8 below, can be contacted using the following contact details: Opera Universitaria di Trento, Via della Malpensada n. 82/A, 38123 Trento
Fax: +39 0461.217444 – Certified Email: operauniversitaria@pec.operauni.tn.it – Email: referenteprivacy@operauni.tn.it – Telephone +39 0461.217411.

We also inform you that a Data Protection Officer has been appointed, who can be contacted at the following email address: dpo@operauni.tn.it.

Rights of the interested party

At any time, where exercisable by you, pursuant to art. 7 of Legislative Decree 196/2003 and Articles 15 to 22 of the Regulation, you will have the right to:

• request confirmation of the existence or otherwise of your personal data
• obtain information regarding the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, where possible, the retention period
• obtain rectification and erasure of data
• obtain restriction of processing
• (where applicable) obtain data portability, i.e., receive the data from a data controller in a structured, commonly used and machine-readable format, and transmit the data to another data controller without hindrance
• object to processing at any time, including in the case of direct marketing purposes
• object to automated decision-making concerning individuals physical, including profiling
• Ask the data controller for access to personal data and the rectification or erasure of such data, or the restriction of processing concerning you, or to object to such processing, in addition to the right to data portability
• Withdraw consent at any time, without prejudice to the lawfulness of processing based on consent before its withdrawal
• Lodge a complaint with the Italian Data Protection Authority, located in Rome, Piazza Venezia 11, the Authority’s official website is garanteprivacy.it

The exercise of these 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 Elisa Lagni – email: dpo@operauni.tn.it