Pursuant to Article 13 of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data (hereinafter referred as “GDPR”), the processing of personal data will be based on principles of correctness, lawfulness and transparency and protection of the privacy and rights of the data subjects.
- Data Controller and Data Protection Officer
The Data Controller is the Sicilian Region – Regional Department of Education, University and the Right to Education, Viale della Regione Siciliana, no. 33 – 90129 Palermo Italy; Certified Electronic Mail (CEM): email@example.com.
The Data processor is INDIRE, National Institute of Documentation, Innovation and Educational Research, with headquarters in via Michelangelo Buonarroti no. – 50122, Florence, Italy, fax 055-2380395, Certified Electronic Mail (CEM) firstname.lastname@example.org.
Data Protection Officer (DPO)
Pursuant to article 37 of the GDPR, the Data Controller is Mr. Antonio Valenti, General Manager of the Regional Department of Education, University and the Right to Education, domiciled for the office at the Regional Department of Education, University and the Right to Education, Viale della Regione Siciliana, no. 33 – 90129 Palermo Italy who can be contacted at the following certified email address: email@example.com
- Purpose and legal basis of the processing of personal data
The site was designed with the main function of providing information on the actions related to the agreement stipulated between the Sicilian Region and Indire, as part of the internationalization of the Sicilian education system. Therefore, in general, the site does not collect personal data. When the need to collect personal data arises – which the user is always free not to provide – a specific information notice is immediately issued. This information notice is drawn up in accordance with Italian and EU law and includes, among other things, the specific purposes of the collected data. We recommend that you read the notice before providing your data.
In all cases, any personal data provided (personal data, contact details, educational details, identity document details, images and audio-video footage) will be processed for the following purposes:
- for the realization of the purposes and initiatives related to the Study in Sicily website, which promotes the training offer of Sicilian Higher Education for Mediterranean countries students, and encourages the collaboration and exchange between institutes, organizations and institutions in Sicily and in the Mediterranean countries.
- for the fulfilment of the institutional purposes of the National Institute of Documentation, Innovation and Educational Research (“INDIRE”), and in particular for statistical and scientific, educational and didactic research purposes;
- to fulfil the obligations established by national law or by communitarian legislation or to comply with any orders from the Managing Authority or other Public Authorities.
The legal basis of the data processing pursuant to art. 6 of EU Regulation no. 2016/679 consists in the execution of a task of public interest and, with particular regard to the dissemination of images/videos, in the manifestation of the specific consent of the interested party or of the person exercising parental authority (where appropriate, always specifically requested).
- Processing methods
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are kept for the minimum period required by current legislation. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the site.
Data provided voluntarily by the user for particular initiatives/services
In particular, INDIRE, on behalf of the Data Controller, may proceed with the collection, storage, processing, dissemination and publication of images, audio/ video recordings and personal data, as part of the agreement with the Sicilian Region and the Study in Sicily project through the dedicated portal, its own institutional website, the Facebook page or other social channels/platforms, publications, and other initiatives promoted by INDIRE and/or the Sicilian Region, also in collaboration or on behalf of other public bodies or administrations for reasons of public interest.
In all cases, INDIRE undertakes not to use the images/videos in contexts that could compromise personal dignity and/or decorum and for uses and/or purposes other than those indicated above.
All data are mainly processed with automated computer procedures on servers located at INDIRE’s offices, or by archiving in the SPC CLOUD system with data centres in Italy. The data may also be processed in non-electronic mode with the aid of manual tools.
There is no transfer of personal data to non-EU countries, without prejudice to the possibility of dissemination of the same in the manner and for the purposes indicated above.
- Data retention period
The data will be kept for the time necessary to achieve the purposes for which they were collected.
The data retention period cannot be less than 5 years, possibly extendable for another 5 years in relation to the evolution of the project’s activities.
This period is determined in such a way as to guarantee the correct storage of data on paper or electronic media for the time defined by EU and national regulations in force on the conservation of administrative and accounting documentation.
- Provision of data and consequences of any refusal
The provision of personal data is optional. However, it should be noted that failure to provide data, and partial or incorrect provision of such data, will result in the impossibility for the data subject to participate in the initiatives related to the Study in Sicily project.
- Communication and dissemination of personal data
The data may be processed and/or communicated to Indire’s staff, and/or to the Data Controller in charge of technical support for the digital platform, to researchers and authorized collaborators, who are also required to respect confidentiality and privacy, and are duly instructed and trained on the principles of current legislation on data protection.
With the prior consent of the data subject, the images and videos released may also be published and disseminated on the internet or on social networks, for educational and/or illustrative purposes, within the limits and for the areas further described in the specific disclaimer and with the processing methods described above. The data provided may be shared with public third parties (Ministry of Education, Ministry of University, Ministry of Foreign Affairs, European Commission, Educational Institutions, and other Public Administrations) always for research purposes and within the institutional purposes of the data controller.
The data may also be entrusted to third-party companies operating in the ICT sector appointed as Data Processors.
No automated processing or profiling of the personal data provided is performed.
- Rights of the data subject
At any time, the data subject may exercise, where applicable, his/her rights towards the Data Controller pursuant to Articles 15-22 of EU Regulation 2016/679, namely the right to:
– access to personal data;
– request the rectification of the same when they have been transcribed incorrectly;
– ask for the updating and/or integration of their data when they have changed;
– ask the data controller to transform data into anonymous form or to block them;
– ask the data controller to cancel data or the application of the right to be forgotten, where appropriate;
– ask the data controller to limit the processing because, for example, some data exceed those necessary to carry out the purpose for which they were collected;
– ask the data controller for data portability, namely transferring their data to another controller without any additional charges or expenses to be borne by the data subject;
– oppose the processing for legitimate reasons;
– withdraw the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation;
To conclude, the data subject has the specific right to lodge a complaint with the Italian Data Protection Authority, based in Rome, Piazza Venezia n. 11.
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Types of cookies
- technical cookies, strictly necessary to make the website work and to provide the service offered and requested by the user;
- profiling cookies, used to create user profiles based on their choices and preferences, in order to send advertising messages in line with the profile created.
Cookies used by this site and their purposes
- anonymous analysis cookies;
- third party cookies;
We use the data collected with cookies in order to offer the user the best possible experience on the website (Cookies on site performance). The cookies generated by navigation are used exclusively for statistical purposes (Anonymous analysis cookies), not allowing the identification of individuals.
It will also be possible that third parties may set their own anonymous cookies (third-party cookies) on some pages of the site, in order to track the operation of their application, or to customize the latter, modulating it on the user’s tastes and preferences. Indire will not be able to access these cookies. By way of example only, www.indire.it allows the sharing of contents on the main social networks, such as Facebook, Flickr, GooglePlus, LinkedIn, Pinterest, Twitter, by users’ clicking on the dedicated icon: in doing so, the social network that created the button will record the user’s action.
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