Re-Generation – Privacy Statement

PRIVACY STATEMENT
PERSUANT TO ART. 13  OF THE 2016/679 EU REGULATION
ON THE HIGH VOCATIONAL TRAINING COURSES (SLP) FOR THE PERSONNEL
OF ENEL S.P.A.
* * *

1. Premise

   The European Union 216/679 Regulation protects all physical people as regards the treatment of their personal data that is carried out by the controller of the treatment, based in the territory of the European Union.
   The above-mentioned Regulation defines the "Data Controller" as the natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the treatment of personal data.
   The purpose of this document is to inform on how the personal data of those who enroll in the high level vocational training courses (SLP - Short Learning Programs) devoted  to ENEL S.p.A. personnel and participate in the distance learning activities, including the final exam, are treated.

2. Information on the Controller of the Treatment

   The International Telematic University UNINETTUNO (hereafter referred to as “UNINETTUNO”) is a non-state distance university, authorized as per Min. Decree 17/04/2003 to deliver academic titles pursuant to art. 3 of the Min. Decree of the 22/10/2004 n° 270 that carries on distance teaching and training activities.
   UNINETTUNO is, pursuant to the EU Regulation 2016/679 the Controller of the treatment of the personal data of the students enrolled to its distance teaching and training courses.
   The person responsible for data protection (RPD/DPO) is Lawyer Gaetano Giordano who can be contacted via e-mail at the following address: dpo@uninettunouniversity.net or by tel./fax at the following number: +390637511524. The concerned people can contact him as regards any matters related to the treatment of their personal data and to the exercise of their rights ensuing from the above-mentioned Regulation. He has the duty of confidentiality as regards the performance of his functions.

3. Aims of the treatment

   UNINETTUNO collects, through the online registration procedure, the personal data of the interested parties in order to finalize their enrolment in the advanced training courses (SLP - Short Learning Programs) devoted to ENEL S.p.A. personnel. Some of the requested information is necessary and its lack would prevent the conclusion of the procedure and therefore the delivery of the course.
   The personal authentication credentials and the e-mail account, assigned to each student, are used by the Controller to allow access to the e-learning platform and to use the training services (didactic cyberspace) of the chosen SLP course, as well as for web-based communications with the tutor or the University.

   The papers and the results of the exercises carried out by the student, the web-based communications with the teachers and tutors, the images and the sounds transmitted during the lessons in the interactive classes or the final exam at a distance are treated by the Controller in order to provide the training activity and to assign the training credits.

4. The profiling activity and the existence of an automatized decision-making process.

   The student's activity in the didactic Cyberspace (number of accesses to the video library and media library, number of exercises done and their average evaluation/self-evaluation) is traced in order to profile this behavior and allow the tutor to express an evaluation for admission to the final exam based both on these quantitative elements and on qualitative elements learned during synchronic and diachronic tutoring activities with the student.

   Therefore, the decision-making process for exam admission is not automated, nor is it based solely on student profiling.
   The number of minutes of each single video lesson of the course viewed by the student is instead traced in order to measure the student's participation, since the decision-making process to establish that the full payment of the course cost is borne by ENEL S.p.A. is based solely on the detection, made by UNINETTUNO learning analytics systems, of the minimum number of minutes of viewing of each videolesson, set at 70%, to be reached by the end of the pre-established delivery period (decision based solely on automated processing).
   The report generated by the learning analytics systems certifies the correct participation of the student and is communicated to ENEL S.p.A. only if the minimum attendance rate of the SLP course is reached.

   Each student gives his consent to this kind of processing and always has the possibility to check, within his or her own reserved area of the didactic cyberspace, the tracing activity in real time and promptly report to UNINETTUNO any malfunctioning or difficulty.
   The refusal to process these personal data or the revocation of the consent given, occurred before the communication of the report, or, finally, the failure to reach the minimum attendance rate, will prevent ENEL S.p.A. from making the full payment, as well as the continuation of the course by the student.
   However, the student has the possibility to continue the activities of the chosen SLP course, participate in the final exam and earn the training credits, paying the remaining cost instead of Enel S.p.A.

5. Juridical bases of the treatment

   The collection, registration and processing of the personal data of those who enroll in the high level professional training courses (SLP - Short Learning Programs) devoted to ENEL S.p.A. personnel are based on

   1. on the express consent of the interested party;
   2. on the necessity of the Controller to execute a contract to which the data subject is a party;
   3. on the necessity of the Controller to fulfill a legal obligation connected to the verification of the admission requirements to the training courses, established by the Ministerial Decree of 22 October 2004 no. 270.
6. The recipient of the personal data

   The data identifying the interested party and those relating to his or her career as a student are communicated to MIUR for statistical purposes related to the keeping of the National Register of Students and Graduates established by Ministerial Decree n. 9 of 30 April 2004.
   The personal data of the interested party will not be transferred outside the European Union or the European Economic Area, nor to an international organization.

7. The period of conservation of personal data

   All the personal data of the interested party will be kept by the Controller for the entire duration of the course and at its end those related to economic aspects will be archived until the expiry of the ordinary terms of prescription referred to in art. 2946 c.c. and then deleted, while those related to the student's career, being inherent to an administrative procedure, will be kept exclusively for archiving purposes in the public interest for an unlimited period of time.

8. Rights of the concerned person

   Every concerned person has a right to ask for the:

   • access to and rectification of inaccurate personal data concerning him;
   • the integration of incomplete data;
   • the cancellation of the same if they have been processed unlawfully or if the cancellation is necessary to fulfil a legal obligation;
   • the limitation of the processing only to personal data concerning him for which the person concerned does not contest the accuracy, pending the completion of the checks on those contested and to be informed before such limitation is revoked;
   • the delivery of the personal data he provided, in a structured format, commonly used and readable by automatic device, or the transmission of the same data to another data controller, even in a direct way, if technically possible. Excluded from this right are personal data that have not been provided by the data subject and those processed for the performance of a task carried out in the public interest or in connection with public powers vested in the Data Controller.

Moreover, at any time, the data subject has the right to object, pursuant to Article 21 of EU Regulation 2016/679, to the processing of his personal data carried out on the basis of a legitimate interest, giving legitimate reasons related to his particular situation.
All requests can be forwarded to UNINETTUNO at the registered office, or to the following addresses:
tel.:+39 06 692076.70 | +39 06 692076.71 or e-mail info@uninettunouniversity.net.

In the event that the data subject considers that the processing concerning him is in breach of EU Regulation 2016/679 or that the Data Controller did not comply with its obligations related to the exercise of the aforementioned rights, he has the right pursuant to Article 77 of the same Regulation to lodge a complaint with the Supervisory Authority located in the Member State where he normally resides or works, or with the one located in the place where the alleged breach occurred. This is without prejudice to any other administrative or judicial recourse.