Policy for institutional events in online or blended mode

PRIVACY POLICY AND DECLARATION OF CONSENT TO PERSONAL DATA PROCESSING UNDER ART. 13 OF REGULATION (EU) NO. 2016/679 OF 27 APRIL 2016

This policy is issued under Art. 13 of Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and in respect of the laws on personal data processing and on the free movement of such data.

 

Data Controller

Politecnico di Milano – Director General, delegated by the pro-tempore Rector – e-mail: dirgen@polimi.it.

 

Internal Processor

Ms. Gloria Paoluzzi, Department Manager of the Architecture and Urban Studies Department, Piazza Leonardo da Vinci 32, Milan (MI), tel. +39 0223995550, email: gloria.paoluzzi@polimi.it. The personal data will be processed by other authorised parties who will receive instructions for that purpose under current legislation.

 

Data Protection Officer and contact details

Mr. Vincenzo Del Core, ph.: +390223999378, email: privacy@polimi.it

 

Processing purposes and legal basis, categories of data and storage period 

The Department’s events are delivered in blended mode through platforms such as (merely by way of example) Cisco Webex, Microsoft Teams and Zoom; registration, where applicable, will be later published on the social channels such as (merely by way of example) Facebook, Twitter, YouTube, LinkedIn and Instagram) and/or on DAStU and satellite websites.
Under the relevant European and national legislation (EU Regulation 2016/679, hereafter Regulation), we inform you that the personal data provided directly by the interested party will be used for the following purposes:

Table 1

 

Personal data processing purposes	Processing legal basis	Personal data categories	Personal data retention period
Purpose 1 Register for and participate in the event and receive the link to the platform used	Consent (Art. 6, paragraph 1, letter e) of the EU Regulation)	·  • Identification data (name, surname, professional title, affiliation to body/company) ·  Contact details (email address, telephone number)	Data will be stored for five years from the event date.
Purpose 2 Live streaming and possibly, transmission via the Department’s web channels and social media	Public interest for institutional purposes (Art. 6, paragraph 1, letter e) of the EU Regulation)	· Identification data (surname, name) ·  Images and voice	The recording will be stored throughout the period of the event
Purpose 3 Recording the event for reposting on the institutional website and through the Department’s official communication channels allows users to see the event, albeit not live	Public interest for institutional purposes (Art. 6, paragraph 1, letter e) of the EU Regulation)	·  Identification data (surname, name) ·  Images and voice	The recording will be retained for five years from the event date
Purpose 4 Acquisition of contacts for the communication of events and institutional activities of the Department (creation of mailing lists)	Consent (Art. 6, paragraph 1, letter e) of the EU Regulation).	· Personal data (name, surname, professional title, affiliation to body/company) · Contact details (email address, telephone number)telefono)	The recording will be retained for five years from the event date
Purpose 5 Statistical purposes, storage and archiving	Performance of Politecnico di Milano’s institutional activities (Art. 6, paragraph 1, letter e) of the Regulation	· Personal data (name, surname, professional title, affiliation to body/company) · Contact details (email address, telephone number) · Images and voicevoce	The data necessary for the correct functioning of the public administration will be archived and stored indefinitely, in compliance with the principles of transparency, lawfulness, proportionality and minimisation

 

If the participant has a disability, under Art. 9, para. 2, letter a) of the EU Regulation, it is possible to give notice of this during registration, to take organisational measures for the smooth participation in the initiative. The processing of this data has its legal basis in the data subject consent.

Please note that during the events, the participant who speaks, assumes responsibility and exonerates Politecnico di Milano from any liability for the dissemination of the image or audio during the event and afterwards.
If the event is recorded, and a participant speaks during the event, they will be video or audio recorded.

The processed data, including images of filming and audio/video recordings, even in partial, modified or adapted format, made during the initiative will be processed in respect of the EU Regulation.
The data will be electronically processed by appointed persons for dissemination and communication activities on the Architecture and Urban Studies Department web, social media and streaming channels.
The images collected will be stored, even electronically and on any technological medium, for the purposes and within the limits defined above, and may be disseminated under Law no. 150/2000 on institutional websites and through social media networks (for example, Facebook, Twitter, YouTube, LinkedIn, Instagram). The use of images does not give any right to any remuneration.
The Architecture and Urban Studies Department has the right to access or disclose the images without obtaining any consent, under Art. 97 of Italian Law no. 633/1941. This authorisation implies the granting of a non-exclusive licence, without time or geographical limits, transferable to third parties, for use of the Materials, and includes the rights referred to in Articles 12 to 19 of Italian Law no. 633/1941, including but not limited to: right of publication; right of reproduction in any way or form; right of transcription, editing, adaptation, processing and reduction; right of communication and distribution to the public, including projection, transmission and broadcasting rights even in summary and/or reduced version, using any technical means, right to keep a copy of the Materials, even in electronic form and on any known or future technological system for the purposes and within the limits defined above. Under the above article and art. 10 of the Italian Civil Code, any use of the images that may cause prejudice to the honour, reputation or decorum of the person portrayed, taken or recorded, is excluded.

 

Nature of the data

Providing data is optional.
Refusal to provide data for Purpose no. 1 listed in Table 1 will make it impossible for you to register and participate in the events.

 

Data processing methods

Only in case of participation in the live stream via platforms such as, (merely by way of example) Cisco Webex, Microsoft Teams and Zoom, the participation may involve – if the event is recorded – the individual’s video recording as well as the possible collection of audio if the data subject takes an active role in the initiative.
The recording involves using the features available from the platform used to allow the video conferencing to take place as well as the broadcast of the recording on the Architecture and Urban Studies Department’s web and social media. The video recording will be stored on servers owned by Politecnico di Milano.
All these operations will be carried out by methods aimed at guaranteeing the utmost security and confidentiality by persons specifically instructed for that purpose by Politecnico di Milano.
For the purposes indicated in Table 1, the personal data will be processed on digital media using electronic or automated tools on the hard drive of Politecnico di Milano. They might also be stored in digital format on an open-ended basis based upon the obligations of transparency and proper functioning of the public administration.
Access to the data acquired for the purposes in Table 1 is permitted only to authorised personnel who have been given appropriate operating instructions, i.e. Tutors, relevant offices and support staff for organisational activities.

 

Categories of recipients

The privacy policies for the management of personal data relating to the third parties indicated above are available at the following addresses:

• Google e YouTube: https://policies.google.com/privacy?hl=it;
• Facebook: http://www.facebook.com/privacy/explanation.php;
• Instagram: https://help.instagram.com/519522125107875;
• Twitter: http://twitter.com/privacy;
• Linkedin: http://www.linkedin.com/static?key=privacy_policy&trk=hb_ft_priv.

Personal data may be communicated to other public administrations, including anonymously, if they need to process the data for their own institutional purposes, and to all public parties to whom, in the presence of the relevant conditions, the communication is mandatory under European law, standards or regulations, and to insurance companies for any accidents that may occur.

 

Special categories of data

Under Articles 9 and 10 of EU Regulation no. 2016/679, data qualifying as “special categories of data” particularly information relating to conditions of disability declared by the data subject during registration.

 

Transferring data to non-EU countries or international Organisations

In relation to the Purposes indicated in Table 1, the data will not be transferred in any way to non-EU countries or to international organisations.
If for technical or operational reasons it becomes necessary to use parties located outside the European Union, or transfer some of the data collected to technical systems and services managed in the cloud and located outside the European Union, the processing will be regulated under the provisions of Chapter V of the EU Regulations and authorised based on EU decisions. Precautions will be taken to ensure the most complete protection of personal data, basing such a transfer: a) on adequacy decisions of the receiving third-party countries expressed by the European Commission; b) on adequate safeguards expressed by the receiving third party under art. 46 of the Regulation; c) on the adoption of so-called “corporate binding rules”.

 

Data subject rights

The data subject may at any time request from the Controller:
• confirmation of the existence or their personal data;
• access to their personal data and related information; correction of inaccurate data or supplementation of incomplete data; deletion of their personal data (under one of the conditions indicated in Art. 17, paragraph 1 of the Regulation and subject to the exceptions envisaged by paragraph 3 of that Article); the restriction of processing of their personal data (in the presence of one of the circumstances indicated in Art. 18, paragraph 1 of the Regulation), the transformation into anonymous form or block on data processed in violation of the law, including data whose storage is no longer necessary for the purposes for which it was collected or processed.
The data subject also has the right to object in full or in part:
• on legitimate grounds, to the processing of their personal data, even if it is relevant for the purpose for which the data was collected;
• to the processing of their personal data, for the purposes of sending promotional material for Politecnico di Milano training initiatives and cultural events.

These rights may be exercised by contacting privacy@polimi.it.

If the data subject believes that their rights have been violated by the Data Controller or a third party, they can lodge a complaint with the Data Protection Authority, or another relevant supervisory authority under the Regulation.

By ticking the appropriate boxes on the online event registration form, the data subject expresses their free and full consent to the data processing for each of the purposes indicated in the policy within the limits in which their consent was legally required for its communication to parties listed in the same policy.

The data subject may withdraw consent at any time. The withdrawal of consent will not affect the lawfulness of the processing based on the consent before withdrawal. The data subject shall be informed before giving their consent. The granting and revocation of consent are equally unproblematic.

 

accordato.