PRIVACY POLICY - LINK CAMPUS UNIVERSITY

PRIVACY POLICY

Informative Report and request of consent for the processing of the personal data according to art. 13 of the Privacy Code and arts. 13 and 14 of the GDPR 2016/679 (General Data Protection Regulation)

“Link Campus University” adopts the necessary measures for the application of the European Regulation 2016/679 GDPR (General Data Protection Regulation), and the national legislation in force, relating to the protection of the individuals as to the processing of the personal data. As a matter of fact, it should be noted that the European Regulation 2016/679, concerning the protection of the individuals as to the processing of the personal data, has been in force since 25 May 2018.

For personal data we mean:

• Identifying data, which declare the identity of a person;
• Sensitive data, which reveal the racial and ethnic origin, the religious belief, the philosophical convictions or any other type of convictions, the political opinions, the support to parties, trade unions, religious, philosophical, political or trade-union associations or organizations, as well as the personal data suitable to disclose the state of health and the sex life.
• Judicial data disclosing criminal records, administrative sanctions deriving from crimes and the relevant pending suits or the position as defendant or suspect pursuant to articles 60 and 61 of the criminal procedure code;

 

Controller of the data processing

The controller of the data processing is the Link Campus University, in the person of its pro-tempore legal representative, the Rector, domiciled for the exertion of his office at the University.

 

Data Protection Officer (DPO)

The data protection officer is a figure provided by art. 37 of the (EU) Regulation 2016/679. He is a person designated by the Controller of the data processing to carry out offices of support and control as well as advising, training and information tasks in connection with the application of the Regulation, as for example:

to inform and advise the controller as well as the employees who carry out processing as to the obligations pursuant to GDPR, as well as other National or Union provisions concerning the protection of the data;

a. to monitor compliance with this Regulation (GDPR), other national and Union provisions concerning the protection of the data as well as the policies of the controller or processor in relation to the protection of personal data, including the assignement of responsabilities, awareness-raising and training of staff involved in processing operation, and the related audits;
b. to provide advice, if requested, as regards the data protection impact assessment and monitor its performance pursuant to article 35 of GDPR;
c. to cooperate with the Supervisory Authority for the protection of the personal data;
d. to act as the contact point for the Supervisory Authority on issues relating to processing.

 

Controller of the data processing (DPO)

Mrs Giulia Scotti
Tel. + 39 06 94802283
e-mail: Rdp@unilink.it
PEC: lcu@pec.unilink.it

 

Processed Data

Pursuant to art. 13 of the Leg. Decree no. 196 dated 30 June 2003, Link Campus University informs that the personal and the identifying data concerning the data subject are managed by the Administration Office, in order to comply with the legal. requirements. The processed data are as follows:

a) personal, identifying and informative data required in the enrolment application form, including the data relating to the qualification for the access to the University courses;
b) data concerning the intermediate and final school achievements, or however connected with the university career;
c) data relating to the different-abled students;
d) data concerning income elements for the purpose of exemptions from the payment of tuition fees.

 

We point out that among the processed data there are those described as:

• “judicial data” pursuant to art. 4, paragraph 1, letter e) of the Leg. Decree 196/2003 and specifically: suitable personal data to disclose the provisions under art. 3, paragraph 1, letters from a) to o) and from r) to u) of the Presidential Decree no. 313 dated 14 November 2002;
• “sensitive data” pursuant to art. 4, paragraph 1 letter d) of the Leg. Decree 196/2003.

 

Purposes of the processing and legal basis

The processing of the personal data requested to the data subject is carried out according to art. 6 letter e) of the EU Regulation 2016/679, for the following purposes:

• enrollment and attendance in the University courses requiring attendance or e-learning courses;
• management of the university career;
• use of career guidance services;
• obtainment of the qualification;
• calculation of the amount of taxes due;
• use of telematic and e-mail services;
• use of the librarian services;
• access to laboratories and other protected structures;
• fruition of financial aids , facilities and services in connection with the right to university study;
• application of safety measures for workplaces according to the provisions set out in the Legislative Decree 81/2008;
• transmission of communications concerning his/her university career;
• surveys for the evaluation of teaching and customer satisfaction;
• archiving and storage of documents concerning the university career and research activity, both as to the studies carried out and the positions held and the qualifications obtained;
• elections of his/her representatives and for carrying out tasks concerning the elective office held by the data subject in the University government bodies;
• statistics and historical and scientific research, anonymously;
• use of facilities concerning the chronic and temporary disability of the data subject.

Moreover, we have planned the (non compulsory and subject to consent) processing of the identifying and university career personal data for the following purposes:

• transmission of communication to public and private subjects for employment and cultural purposes.

The personal data may be communicated to other public subjects when it is necessary for carrying out University institutional functions requested by the data subject, as for example public entities in charge of the management of grants for research and sholarships.

The controller of the data processing does not use automatic processes aiming to the profiling of the data subject.

 

Place and methods of the data processing

“Link Campus University” informs that the above-mentioned data will be processed either in paper or electronic format, through the storage of the data both in archives and in data banks only for as long as is strictly necessary to achieve the goals the data were collected for and, however, in compliance with the principles of lawfulness, fairness, non- excessiveness and pertinence required by the current privacy legislative provisions.

Moreover the personal data relating to the university career will be kept indefinitely, considering the storage obligations imposed by the legislation in force. The other collected data for the use of the services and the communications will be kept for the time established by law in force and the University regulation.

 

Recipients of the personal data

The personal data provided by users may be communicated to third parties only if necessary, other public subjects (for example the Ministry of Education, Universities and Research, Ente Regionale per il Diritto allo Studio Universitario, (Regional Body for the Right to the University Study) , Osservatorio Regionale per l’Università e per il diritto allo Studio Universitario (Regional Observatory for the University and the Right to the University Study ), Ministry of Finances) that manage the grant of research contributions and/or scholarships or promote studies and research, projects for the University development and the services for the right to study.
Furthermore, the personal data are communicated to the bank that, in agreement with the University, manages the collections of the taxes and the university fees.
The personal data of the data subject will be processed within the University by the professors of the chosen study field and the technical-administrative staff pertaining to the competent structures for the different types of processing.
The personal data of the data subject may also be communicated to public and private companies where educational or research activities or training concerning the chosen study field might be carried out.
The personal data of the data subject might also be communicated to foreign universities as part of the programs of student mobility for the purposes laid down in this Informative Report.
The personal data of the data subject might also be communicated to other public administrations, if they have to process the data for activities of their institutional competence.
Moreover, the personal data of the data subject are also communicated to the University, either during the university career or after the obtainment of the relevant study qualification, external subjects, bodies and associations, for initiatives of vocational guidance and entry into the labour market and for post-degree training activities.
The transfer abroad of the data subject’s personal data to EU-extra countries will take place in compliance with the provisions laid down in Chapert V, GDPR (art. 46). In such circumstance, Link Campus University guarantees the adoption of adeguate guarantees (as the signing of standard contract clauses approved by EU Commission) with EU-extra legal subjects receiving the data; such clauses guarantee a protection level of the data corresponding to that sanctioned by the European Regulation.

 

Rights of the Subject data

The New European Regulation as to the protection of the personal data (2016/679) guarantees that the data subject has:

1. the right to obtain confirm or denial of the existence of the personal data concerning him/her, even if they are not registered yet;

2. the right to know:
a) the origin of the personal data;
b) the purposes and the modalities of the processing;
c) the applied logic in case of processing carried out by electronic means;
d) the identifying data of the controller, the persons in charge of the subjects or categories of subjects the personal data may be communicated to or who may get information about them.

3. the right to obtain , by the controller or the person in charge, without delay:
e) the update, the rectification, or ,if pertinent, the integration of the data;
f) the erasure, the transformation in anonymous form and the block of the data processed in breach of law, including those whose conservation is not longer necessary in connection with the purposes for which they were collected or later processed;
g) the declaration that the operations under the previous letters a) and b) have been brought to the attention, also as to their contents, of those the data were communicated to, except for the case in which such fulfillment is impossible or entails a use of means clearly out of proportion to the protected right.

4) The right to object in part or fully:
h) for lawful reasons to the processing of the personal data concerning him/her, even though relevant to the purpose of the collection;
g) to the processing of the personal data concerning him/her, for the purposes of sending advertising material or direct sale or for the conclusion of market researches or commercial communication.

5) Moreover, pursuant to art. 7 paragraph 3 , GDPR, at any time the data subject may exercise his/her right of consent revocation without that the lawfulness of the processing based on the previously given consent is jeopardized;

6) Finally, the data subject has the right to lodge a complaint before the Control Authority, that is the Data Protection Supervisor in Italy. In order to exercise such rights, point out problems or request clarifications on the processing of his/her personal data the person concerned can write to rdp@unilink.it.

 

Right to be forgotten

This informative report concerns only the processing of the personal data that the data subject has provided or will provide to Link Campus University – also purchasing our products and/or services supplied on payment or taking part to our promotions and/or offers - and those that, Link Campus University will acquire during the present relationship and/or further relationships. Instead the subject data who intends to assert his/her right to be forgotten has to write to rdp@unilink.it.

 

Update of the Privacy Policy

The entry into force of new sectoral provisions as well as the constant exam and update of the user services, might entail the necessity to change the modalities and terms described in this Informative Report. Therefore, it might be that such document may be modified over time. Thus we reserve the right to change the present Privacy Policy in the event of adjustments or updates of which the data subject will be informed.