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Service Privacy Policy

With the entry into force of Regulation (EU) n.2016 / 679 (hereafter also 'Regulation') relating to the protection of individuals with regard to the processing of personal data, the Ministry of the Interior, as data controller of personal data resulting from consultation of the pages of the portal 112sordi.it and registration of users to the 112 Deaf service, adopts technical and organizational measures to ensure that it complies with the rules and principles provided for by the Regulation.
This information, made in application of article 12 of the Regulation, intends to inform users of the portal, pursuant to article 13 (Information to be provided if personal data are collected from the interested party), regarding the processing of personal data conferred by them.

1. Data controller

The data controller is the Ministry of the Interior
Address: Piazza del Viminale, 1, 00184 Rome – Italy
Switchboard: +39 06 4651.
WEB site: www.interno.gov.it

2. Data protection officer

3. Supervisory authority

Guarantor for the Protection of Personal Data
Switchboard: +39 06.696771.
E-mail: garante@gpdp.it
PEC: protocollo@pec.gpdp.it
WEB site: www.garanteprivacy.it

4. Legal basis of the processing

The Ministry of the Interior processes personal data in the performance of its public interest tasks and in any case in the exercise of its public powers.
Subscription to the 112 Deaf service by the user is optional and voluntary. The legal basis for the processing of personal data lies in the contract of use (article 6 paragraph 1 letter of the Regulation) accepted by the user during the registration phase.
However, the type of service and the purpose explained by the portal imply, even indirectly, the association of the user's identification data with the condition of person suffering from hearing impairment. For this reason, the user is asked for consent to the processing of particular categories of personal data pursuant to Article 9 paragraph 2 letter a. of the Regulations.

5. Description of the service

The service allows operators of 112 and Italian emergency numbers to know that the person who is asking for help is deaf. In this way, the respondent implements all the necessary precautions to intervene in a useful and appropriate way, without wasting time and without the need for intermediaries.
In order to be rescued faster, the emergency number operator knows thanks to the call sign, that the interlocutor is deaf even before answering the phone. In addition, the service saves valuable time as many of the person making the call are already available.
Knowing that the user is deaf, the emergency operator immediately activates a text chat to communicate with the interlocutor. Thanks to the chat, the user of the service will also be able to receive useful images awaiting help and answer extremely simple and fast interactive questions.
In addition, when the user calls the dedicated number or the national single number for emergencies 112, an SMS will be sent to him to start the chat and to be able to detect the geographical position of the caller in order to send help more quickly.
The user's privacy is always protected and his position is collected only against a real request for intervention. The portal does not record and / or store information on the user's location. To register for the service, the user must provide his / her personal data. These will be readable to emergency service operators only in the event of a call.
To register for the service, only the information necessary to manage the account and to identify the user in case of need is required. Following registration, the user can access the service and subsequently modify the data provided during registration, consult or delete them.
If the user logs in with a social profile or with SPID, he will have to enter his data immediately after logging in.

6. Types of data processed and purposes of the processing

  1. LOG data
    The activities of users registered with the service are tracked and stored to allow the necessary security checks. In particular, all access, modification and cancellation operations are stored on personal data. The accesses that the emergency operations centers make to user data in the event of a request for assistance are also traced.
  2. Data provided directly by the user
    The optional, explicit and voluntary sending of messages to the contact addresses of the Ministry published on the portal, as well as the compilation and forwarding of the registration form for the service, entail the acquisition of the sender's contact data and the following personal data:
    • Name and Surname - The fields are mandatory in order to obtain the registration of the user to the service and are necessary to create the user account on the platform and quickly identify the subject in the event of a distress call (e.g. through specific question via chat : 'Are you Name Surname?').
    • Gender and date of birth - The fields are mandatory in order to obtain user registration for the service because, given the difficulty of communication due to the inability to hear or speak the user, it is preferred to collect this information in 'time of peace' to provide adequate assistance without having to further interact, or in any case by reducing the steps with the subject, during the delicate phase of request for help.
    • Address, Municipality and Province - The fields are not mandatory in order to obtain the registration of the user to the service but the information, if provided by the user, can help simplify and speed up the sending of help when the user requests rescue at your residence. During the request for help, the operations center will try to locate the position of the applicant but in the event of impossibility or difficulty in carrying out this operation, the address data can help in the circumstance of home help (eg through specific questions via chat: 'request help at home address'?).
    • E-mail - The field is mandatory in order to obtain user registration for the service and is necessary in order to create the user account on the platform.
      The recorded data must be validated through a special CODE sent to the email address entered in the registration form in order to avoid non-voluntary registrations.
      The data is not communicated to the emergency operations center and is used exclusively by the user to identify himself for the autonomous management of his registration data on the platform and request cancellation from the service or password reset.
      The e-mail address is also used to automatically send a request for confirmation of registration every 24 months in order to clean up the archives from data.
    • Prefix and Mobile phone number - the fields are mandatory in order to obtain user registration for the service and it is necessary for the operations center to immediately identify the caller and activate the appropriate communication procedures.
      The recorded data must be validated through a special CODE sent via SMS to the mobile phone number entered in the registration form in order to avoid non-voluntary registrations.
    • Password - The field is mandatory in order to obtain user registration for the service and is necessary in order to create the user account on the platform. The data is not communicated to the emergency call center and is used exclusively by the user to authenticate himself for the autonomous management of his registration data on the platform and request cancellation from the service.
  3. Particular categories of data
    Given the type of service and the purpose made explicit by the portal, registration on the platform involves, albeit indirectly, the association of your identification data with the condition of person with hearing impairment.
More information - The GPS coordinates of the user, as well as the data relating to the request for assistance, are not processed by the 112sordi.it platform but are directly transferred from the user's device, or from the user himself, to the operations center that takes over I load the request.

7. To whom the data are disclosed

The data may be communicated to:

  1. companies in charge of the management and maintenance of the service that will process the data in their capacity as Data Processors pursuant to article 28 of the Regulation.
  2. Network and telecommunication service providers.
  3. Administrative, institutional and / or judicial authorities and to any other subject to whom communication is mandatory by law and / or for the fulfillment of the purposes indicated in this statement.
Exclusively in the event of a request for assistance from the user, also with regard to third parties, the data will be communicated to:
  1. Operational centers for emergency management integrated with the service

8. Transfer of data to third countries or international organizations

The data processing is generally carried out by subjects operating on the Italian national territory. However, 112 Deaf, uses Cloud services that reside on datacenters located within the European Union. These services are provided by certified operators identified in the AgID Cloud Marketplace. The AgID Cloud Marketplace exposes the services and infrastructures qualified by the Agency for Digital Italy for use by public administrations.

9. Duration of treatment

The processing of personal data will last until the user is deleted from the service.
Treatment is stopped if:

  1. the user voluntarily deletes himself directly through the appropriate function accessible from the control panel through his own account
  2. the user is automatically deleted following the failure to reply to the request for confirmation of joining the service and verification of their data, sent by e-mail every 24 months from the date of registration to the service

10. Data retention period

We will retain personal data for the limitation period provided for by the legislation for the protection of related rights, without prejudice in any case to longer retention periods provided for by specific sector regulations.

LOG data

Log data are stored and processed for a maximum period of 36 months from their collection.

Data provided directly by the user

With the exception of the data provided during the optional, explicit and voluntary sending of messages to the contact addresses of the Ministry published on the portal, which will be kept and processed for the period deemed necessary to meet the request, the data provided by the user in phase to register for the service, are stored and processed only for the duration of the user's registration to the service, or:

  1. the user voluntarily deletes himself directly through the appropriate function accessible from the control panel through his own account
  2. the user is automatically deleted following the failure to reply to the request for confirmation of joining the service and verification of their data, sent by e-mail every 24 months from the date of registration to the service

11. Rights of the interested parties

The interested parties have the right to obtain from the Ministry of the Interior, in the cases provided for by the Regulation, access to their personal data, the correction or cancellation of the same or the limitation of the processing that concerns them, or to oppose the treatment, according to what provided for in articles 15-22 of the regulation. The related requests must be submitted by forwarding them to the Data Controller or to the Data Protection Manager, using the form available at the following link: www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924.

12. Communication of violation of personal data

When the possible violation of personal data may involve a high risk for the rights and freedoms of natural persons, the violation is communicated to the interested party without justified delay, according to the provisions of article 34 of the Regulation.

13. Right to complain

Interested parties who believe that the processing of their personal data carried out following consultation of the portal is in violation of the provisions of the Regulation have the right to lodge a complaint with the Guarantor for the protection of personal data, as a national supervisory authority (article 77), or to appeal in court (article 79).