PRIVACY POLICY ON THE PROCESSING OF PERSONAL DATA FOR THE INTERINSTITUTIONAL HELP DESK AGAINST

ILLEGAL GANG MASTERING, ACTIVATED WITHIN THE P.I.U.SU.PR.EME. (individual ways out of exploitation) PROJECT.

DATA CONTROLLER:

CONSORZIO NOVA not-for-profit organisation of social cooperatives, social cooperative society

Registered office: Via Pedaggio Santa Chiara 57 bis – 76125 TRANI – tel. 0883.031018 – privacy@consorzionova.it

INTERESTED PARTIES AND PURPOSES

Interested parties – Beneficiaries of the interinstitutional Help Desk against illegal gang mastering within the P.I.U.Su.Pr.Eme. project. – individual ways out of exit exploitation. Purposes – A) Provision of the interinstitutional Help Desk against labor exploitation’s service, within the P.I.U.SU.PR.EME. project. – Individualized paths of exit from labor exploitation; this purpose may involve, subject to the consent of the interested party, data transfer to third parties such as social services / trade unions and other bodies; B) Requests by the project’s funding bodies (Ministry of Labour and Social Policies, Directorate General of Immigration and Integration Policies; European Union, NOP Inclusion – European Social Fund 2014-2020) or on behalf of said funding bodies, in the form of aggregated data; C) Support to the interested party in exercising his/her rights if he/she is found to be exploited, in relation to aspects related to labor, social security and social protection legislation; D) litigation management if the case arises

DATA RETENTION PERIOD

For the purposes: a), b), and c) until the provision of service is complete, and in any case in compliance with the deadlines established by the funding bodies, for any inspections / checks or to allow the interested party to exercise his/her right; d) as established by current legislation. The period may be further extended in the event of a dispute or legal controversy. In some cases, cancellation delays may be subject to internal back-up procedures. Retention periods/criteria are documented in the processing register.

DATA PROCESSED AND PROCESSING METHODS

Data processed Personal and contact details, other data to optimize the service (such as: work status, language spoken, etc.). Exceptionally, specific details such as legal status, judicial situation, state of health, conditions of vulnerability, whether related to the exploitation of the interested party or not (such as, for example, information on any deportation orders) may be collected. The information is provided voluntarily, with the understanding that some is required to allow the interested party to best use of the interinstitutional Help Desk against illegal gang mastering of the P.I.U.Su.Pr.Eme. (individual ways out of exploitation) project. Communications to and from operators, as well as those carried out through social networks and instant messaging systems used by the interested party to communicate within the project, are automatically transcribed by the Salesforce platform. Finally, part of verbal communications may be recorded, through the same platform – see the paragraph on consent. In processing personal details which may, directly or indirectly, identify the interested party, Consorzio Nova does so according to the principle of data minimisation and to ensure the confidentiality of the data processed. For this reason, only the data of the interested party necessary to fulfill the Help Desk’s stated purposes are collected. Personal details will be processed electronically by Consorzio Nova, in the manner and within the limits necessary to pursue the aforementioned purposes. All collected data are essential to be able to fulfill the Help Desk’s purposes; specifically, for the purposes a), b), and c) the obligation to provide data is necessary in order to provide the Interinstitutional Help Desk of the Piu.Su.Pr.Eme project’s services requested by the interested party, and to allow the interested parties to exercise their rights in the field of labor, social security and social protection legislation. In addition, only for purpose a), the obligation to provide data to be forwarded to third parties (e.g. social services / trade union representatives / other bodies), the legal basis is represented by the consent recorded electronically through the Salesforce platform. For purpose d) said obligation is necessary to allow the Data Controller to fulfill his/her legal duties. Failure to provide data for the above-mentioned purposes shall entail exclusion from the activities provided by the P.I.U..Su.Pr.Eme.’s Help Desk.

RECIPIENTS AND PERSONS AUTHORIZED TO PROCESS THE DATA

The data may be accessed by authorized personnel, as part of the interinstitutional Help Desk against illegal gang mastering of the PI.U.Su. Pr.Eme. (individual ways out of exploitation) project –of Consorzio Nova, for the purposes of service provision, and for administrative and organizational activities, within the necessary limits, as well as by Consorzio Nova’s system administrators. The data may also be accessed by representatives of the funding bodies or other subjects on their behalf (specifically, only the names of foreign national interested parties with legal status are transmitted, whereas in most cases data are transmitted to funding bodies in aggregate and anonymous form), as entities in charge of inspection services, and by staff of suppliers of the IT support service and of the Salesforce platform. The data may be transmitted to project partners or other members of local or other networks or to other entities, which may contribute to the achievement of the aims of the project. Data transmission to these entities is subject to the interested party’s authorization (consent), as purposely informed by Consorzio Nova’s staff in charge of the service, after registration on Consorzio’s information system. In addition, because some IT system management and maintenance activities are contracted to third parties, the data pertaining to the interested party may be processed by the staff of such third parties who act as external data processors of Consorzio Nova and / or as system administrators, when appointed as such, and who adopt appropriate measures to ensure confidentiality and data protection. Finally, if contact to request the Help Desk’s services and any data exchange takes place through social networks or instant messaging services, the data may be processed by the latter in accordance with their privacy policies, to which reference is made. The request for data exchange through social platforms or electronic messaging services is a free choice of the interested party. The list of third parties who process data on behalf of the Data Controller is available upon request to privacy@consorzionova.it. Access to these data is subject to the assessment of the lawfulness of the request.

DATA SECURITY

Your personal data will be processed with automated tools in compliance with the principle of necessity and proportionality, avoiding the processing of personal data where operations can be carried out through the use of anonymous data or through other methods. Consorzio Nova has adopted specific technical and organizational security measures to prevent the loss of personal data, illicit or incorrect use and unauthorized access.

DATA TRANSFER

As a rule, data transfers outside the European Union are not envisaged. In some cases, your data may be transferred to the USA to Salesforce. This platform will be monitored, and consent will be requested if necessary. For further information, you can visit the following sites:

– https://www.salesforce.com/it/company/privacy/

 – https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data[1]protection/standard-contractual-clauses-scc_en

– https://www.privacyshield.gov/welcome

YOUR RIGHTS

In accordance with the provisions of EU Regulation 2016/679, as far as applicable, the interested party may exercise his/her right to access personal data by contacting Consorzio Nova by e-mail: privacy@consorzionova.it.. The interested party may request the cancellation, correction, , completion, limitation of processing, portability, as well as opposition to processing in the event of a legitimate interest on the part of the data ownerat any time. The interested party, by contacting the above references, may revoke at any time, the consent to the processing of data for one or more of the purposes indicated above. The data subject also has the right to lodge a complaint with the competent Supervisory Authority in the Member State in which he or she habitually resides or in the State where the alleged infringement occurred.

REQUEST FOR CLARIFICATION

In case of doubts, requests for clarification or anything else that may concern the processing of their personal data, the interested party can contact the privacy contact function (0883.031018) or by sending an email to privacy@consorzionova.it

DATA PROTECTION OFFICER

The Nova Consortium, to protect the interested parties, has appointed the Data Protection Officer, with support and control, advisory, training and information functions, cooperation and contact with the Privacy Guarantor Authority for issues related to the processing of personal data. The Data Protection Officer of the Consortium can be contacted at the following addresses: dpo@consorzionova.it

CHANGES TO THE DOCUMENT

The data controller reserves the right to change this disclaimer where necessary, by notifying interested parties in the most visible way possible.

DOCUMENT VERSION

Updated 20th September 2021