Information for those concerned,
Data collected from you will be processed according to the following principles: lawfulness, fairness and transparency; purpose limitation; data minimization; accuracy; storage limitation; integrity and confidentiality.
UNIVERSITA’ COMMERCIALE “LUIGI BOCCONI” (hereinafter referred to as “Bocconi University”), having its registered office in Milano in Via Sarfatti 25, hereby declares that it falls within the field of application of General Data Protection Regulation n. 679/2016 dealing with the protection of personal data (hereinafter referred to as the “Law”), with reference to use of subject’s personal data (hereinafter referred to as “Data”). The former also includes data regarded as “sensitive” (in the broadest sense of the term provided by the Law) namely health, membership of political groups, information related to racial or ethnic origin, handicapped family members, etc., through forms filled in by the data subject while registering to attend promotional events, attended by the data subject before or during the data subject´s academic career, and also in any moment following graduation.
1. The types of information we collect
We may collect the following types of personal data about you:
- your name, contact information such as address, email address and telephone number, as well as your date of birth, tax identification number and your passport number or national identity card details, country of domicile, nationality, as well as your bank data. We may also allocate to you a unique identification number;
- information related to your academic and professional record. We will also keep records related to assessments of your work and other details regarding your professional record. In this sense we will keep the records of the evaluation of your work performance, including teaching evaluation, research impact index and other evaluations academic performance elements;
- information about your personal circumstances, and both academic and extracurricular interests, for example where this is relevant for the assessment of your suitability in the most favorable workplace and in order to connect you with other relevant colleagues and stakeholders;
- Data related to your geographical position limited to the University buildings or urban campus and other activities outside of the campus;
- personal data could be processed also in relation to the attendance at the sport and academic competition events based on merits;
- sensitive personal data: information related to health, including disease and maternity, political opinions, membership of unions and political groups, information related to racial or ethnic origin, etc., shall only be processed for the purposes allowed for by the Law and only for tasks of the University.
2. Modality of the Treatment
The personal data are processed either in paper or electronic format. In the latter case, IT systems will be used. The data will be kept strictly for the time and scope for which they were collected.
Specific security measures are adopted for preventing data breaches, illicit or non-correct uses and non-authorised accesses.
3. Purposes and Processing Data
a) The establishment and development of the labour relationship, as including all processing related to obtain all the activities carried out by internal workers, advisors and external collaborators and professors of different categories. Data will be processed for the activities necessary to fully provide and accomplish the terms agreed
in the labour contract. This shall include planning and controlling of travel costs or verification and control of electronical access; definition of individual development plans; assessment of the services; statistics of presences and absences; management of medical certifications and other documents justify absences; verification of the usage of the telephone in order to attribute related costs and, more in general, for the management of the programme reserved to internal staff and collaborators of Bocconi University;
b) the performance of institutional tasks of the University as well as the performance of activities and communications related to products and services towards which the individual has shown its particular interest, carrying out of institutional events such as ceremonies and related video shots, tasks and obligations connected with the regulations of Bocconi University and as indicated on the Internet. This will also include sending multimedia aids, circulation of periodical publications reserved exclusively for Bocconi University community containing important institutional events, as well as cultural and sport initiatives;
c) for the circulation of periodical publications namely Bocconi News including fundraising and events to support Bocconi University activities in any manner, and in both, printed and electronic format to the email address you provide to us; other editorial/digital/paper activities for communication/promotion purposes of the University requiring the use of images carried out on Campus;
d) for the subscription and attendance at the competition events based on the academic merit;
e) to meet logistic needs, we might process geo-localization data, to ensure more efficiency and to ensure safety;
f) for security and internal organization purposes, including the allocation of the ID card in order to gain access to University services. Moreover, on the same grounds, Data collected may be used for research and statistical purposes. Note also that Data processing for internal organization purposes will include the carrying out of statistical assessments regarding work performance, guidance and actualization of profiles and competences and economic planning;
g) in order to guarantee the transparency, Data related to the performance evaluation could be published to the scientific community, alumni and stakeholders of university;
h) for security and internal organization, verification and control of the informatic accesses; management of the telephone line and of the correspondence, informatic and not, in order to protect the data security, including personal data; activation and deactivation of the electronic badges and password; access regulation to archives and data base; furthermore, for the regulation, verification and control of the accesses to the Bocconi facilities as well as the usage of video surveillance; finally, sharing of the work documentation from Bocconi University staff that could be in need of, for specific tasks developed by and, or hierarchical position sharing; sharing personal information among the staff when it is necessary for the internal organization and service´s needs;
i) for the library purposes, in order to grant the access to, among others, the facilities and materials therein, to borrow books and other products from the library, its consultation and, more in general, to benefit from all the services offered by the library;
j) For the compliance with legal obligations. Note also that the University may pass some of your Data to other organizations if necessary for the detection or prevention of crime or if required by law.
4. Circulation and Communication of Data
The Staff and Professors of University Bocconi will have access to the information that concern them for the execution of their work task or in the capacity of the position they hold, or other subjects that Bocconi University has specifically appointed responsible or in charge of the processing of personal data that are the personnel management, supervisors (and for Professors: supervisors and managers) of other functions that may be required of their performance, also temporarily. Those subjects, in relation to the held office, will have only access to the pertinent Data with said duty.
In addition, the data subject’s data may be communicated to:
a) Public entities both national and international such as ministries and public administration offices, in relation to the performance of the institutional tasks of the University;
b) To natural persons or legal entities, external bodies and associations, including public, professional studios and companies (also outside of the republic of Italy) under the scope of the contract with the data subject and legitimate Bocconi University´s interests. Said data may also be communicated to other legal entities (Istituto Javotte Bocconi, Egea).
5. Granting of Data
The following Data processing will not be subject to your consent: Data processed for security and internal organization purposes; Data for the establishment and development of the labour relationship; Data processing institutional tasks of the University as well as the performance of activities and communications related to products and services that objectively might be of the professional’s interest; Data processing for the library access and services and Data processing for the compliance of legal obligations. Data that is being processed upon your consent might not be needed necessarily but will be significant for us in order to provide some services for your interest.
6. The basis for processing your information and how we use it
We may process your personal data because:
- it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a labour contract, either temporary or permanent;
- it is necessary for the performance of our tasks carried out in the public interest as an academic institution;
- it is necessary for our or a third party's legitimate interests, including security and internal organisation measures and institutional communications;
- your consent has been given, including periodical publications;
- it is necessary to comply with a legal obligation.
7. International data transfers
Some of the personal data we process about you will be transferred to and stored at a destination outside the European Economic Area ("EEA"), for example where it is processed by staff operating outside the EEA who work for us or for one of our suppliers, or where personal data is processed by one of our suppliers which are based outside the EEA or who use storage facilities outside of the EEA.
In these circumstances, your personal data will only be transferred on one of the following bases:
- where the transfer is subject to one or more of the "appropriate safeguards" for international transfers prescribed by applicable law (e.g. standard data protection clauses adopted by the European Commission);
- a European Commission decision provides that the country or territory to which the transfer is made ensures an adequate level of protection; or
- there is another situation where the transfer is permitted under applicable law (e.g. where we have your explicit consent).
8. Data Subject's Rights
Data subjects shall have the following rights:
- to require correcting the personal data we hold about you if it is incorrect;
- to require erasing your personal data;
- to require restricting our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- to receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of your transmittal that personal data to another data controller;
- to object, on grounds related to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you have given your consent and you wish to withdraw it, please contact the responsible of the relevant department using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
9. Contact us
If you have any queries about this privacy notice or how we process your personal data, you can contact our Data Protection Officer at the following e-mail address: firstname.lastname@example.org.
Bocconi University is the Data controller for the purposes of the personal data processed under this policy.