PRIVACY POLICY

For the protection of individuals with regard to the processing of their personal data, Link Campus University adopts the measures necessary for the application of the 2016/679 European Regulation GDPR (General Data Protection Regulation) and the current (Italian) national legislation. The EU Regulation 2016/679, regarding the protection of individuals in relation to the processing of their personal data, has been in force since 25 May 2018.

Personal data means:

• Identifying data, which reveals a person’s identity.

• Sensitive data, which reveals racial or ethnic origin; religious, philosophical, or other beliefs; political opinions; adherence to political parties, trade unions, or associations/organizations of a religious, philosophical, political, or trade-unionist nature; as well as personal data which might disclose details regarding a person’s health condition and sex life.

• Judicial data, which reveals legal measures relating to criminal records; to the register of offence-related administrative sanctions and related pending charges; or to the status of accused person or person under investigation pursuant to Articles 60 and 61 of the Code of Criminal Procedure.

Data Controller. The data controller is Link Campus University in the person of its protempore legal representative, the President of the Link Campus University Foundation, domiciled for this purpose at the University’s headquarters.

Data Protection Officer (DPO). The data protection officer, whose role is assigned by the Data Controller, is a figure provided for in Article 37 of (EU) Regulation 2016/679. The role of the DPO is to support, check, advise, train, and inform in matters relating to the application of the Regulation itself. The DPO:

• Informs and advises the Data Controller, as well as the employees carrying out the processing, regarding the obligations arising from the GDPR, as well as from other national or EU provisions relating to data protection;

• Monitors compliance with the GDPR, with other national or EU data protection provisions, and with the policies of the Data Controller or person in charge of the processing regarding the protection of personal data, including the allocation of responsibilities, awareness-raising activities, and the training of the staff involved in processing operations and related monitoring activities;

• Provides, where requested, an opinion on the data protection impact assessment and monitors its implementation pursuant to article 35 of the GDPR;

• Cooperates with the Data Protection Supervisor (EDPS);

• Acts as a point of contact with the EDPS on matters related to the processing. The Data Protection Officer can be contacted at the following e-mail address: rdp@unilink.it.

Data subject to processing. Link Campus University, pursuant to art. 13 D.lgs 30/06/2003 n. 196, informs you that personal and identifying data concerning students is managed by the Administrative Office for the purpose of fulfilling legal requirements. The following data is subject to processing:

• personal, identifying, and informative data disclosed on the application form, including data relating to the required qualifications for accessing university courses;

• data relating to school grades and results, both intermediary and final, and in any case related to the university career;

• data relating to students with disabilities;

• data relating to income elements for the purposes of possible exemptions from paying university fees

Attention is drawn to the fact that the data subject to processing include those defined:

• Judicial, pursuant to Art. 4, paragraph 1, letter e) of Legislative Decree D.lgs. 196/2003, and namely: personal data revealing the measures referred to in Art. 3, paragraph 1, letters a) to o) and r) to u) of Presidential Decree D.P.R 14/11/2002 n. 313;

• Sensitive data, pursuant to Art. 4, paragraph 1, letter d) of Legislative Decree D.lgs. 196/2003.

Purpose and legal basis of the processing. The processing of the requested personal data is carried out in accordance with Art. 6 letter e) of EU Regulation 2016/679, for the following purposes:

• enrolment and attendance of university courses in person and in e-learning modes;

• university career management;

• access to guidance services;

• achievement of the degree;

• calculation of fees due;

• use of online and email services;

• use of library services;

• access to laboratories and other protected facilities;

• access to grants, funds, and services relating to the right to university study;

• application of safety measures in the workplace in accordance with the provisions of Legislative Decree D.Lgs. 81/2008;

• sending communications relating to the interested party’s university career;

• collection of data regarding teaching assessment and customer satisfaction;

• archiving and preservation of documents relating to the university career, including those with regard to studies carried out, any positions held, and qualifications obtained;

• the election of student representatives, and for the potential carrying out of tasks related to an elected office held by the interested party within the governing bodies of the University;

• statistics and historical and scientific research, in anonymous form;

• any use of disability (chronic or temporary) funds by the interested party.

The processing of personal identifying data and university career data is also carried out for the following purposes:

• communication with public or private external entities for employment or cultural purposes;

• commercial information and the sending of advertising/informative material regarding goods and services, including those belonging to co-owned or connected companies who have a contract and/or agreement(s) with the University, deemed to be of interest to the interested party, both through automated and conventional means, email, and related web applications, upon receiving the interested party’s clear consent.

Personal data may be communicated to other public entities such as public bodies responsible for the management of research grants and scholarships, when such communication is necessary for the carrying out of the institutional functions of the University as requested by the interested party.

The Data Controller does not use automatic processes aimed at profiling the data subject.

Place and method of data processing. The Data Controller hereby informs you that the aforementioned data will be processed in both paper and electronic form, through the inclusion of such data both in archives and in student databases. Furthermore, personal data relating to university careers will be stored indefinitely, taking into account the archiving obligations imposed by current legislation. Other data, collected for the purposes of accessing services or communications, will be kept for the period of time established by current legislation or University regulations.

Recipients of personal data. The personal data provided by users is communicated to third parties only, if necessary, to other public bodies (e.g. Ministry of Education, University and Research; Regional Body for the Right to University Study; Regional Observatory for University and for the Right to University Study; Ministry of Finance) who manage the distribution of research grants and/or scholarships or who promote studies and research; projects for university development, and services for the right to study. Personal data is also communicated to the bank which, in agreement with the University, manages the procedure for collecting university fees and funds.

• Personal data will be processed within the University by the teachers of the chosen course of study and by the technical-administrative staff belonging to the facilities responsible for the various types of processing.

• Personal data may also be communicated to public or private companies where teaching, research, or internship activities relating to the chosen study path may take place.

• Personal data may be communicated to foreign universities as part of student mobility programmes for the purposes indicated in this information notice.

• Personal data may also be communicated to other public administrations, should they need to process the same for any procedures falling within their own institutional competence.

• Personal data will also be communicated by the University, both during the acquisition of information phase and during students’ university and post-graduate careers, to private individuals, external bodies and associations, for orientation and job placement initiatives and for post-graduate training activities; to co-owners and data processing managers as natural or legal persons who, by contract and/or agreement with the University, provide specific teaching or processing services or who carry out activities connected with, instrumental to, or in support of those of the University.

• Any transfer of data abroad to non-EU countries takes place in accordance with the provisions contained in Chapter V, GDPR (Article 46).

RIGHTS OF THE INTERESTED PARTY.

The interested party may at any time exercise the rights referred to in Art. 15 ss. of the Regulation (e.g. request access to data, request the rectification or cancellation of the same, request limitation of the processing of data concerning you, or to oppose the processing of the data, in addition to the right to data portability) by writing a registered letter to the following address:

Link Campus University

Address: Via Matera 18, 00182 Roma

VAT no.: 13343471002

or by sending an email to the following address: privacy@unilink.it.