Covid 19 emergency subsidies - Regional information for seasonal workers on personal data protection

Agreement between the Region of Campania and INPS of 15 May 2020 for the provision of subsidies to seasonal workers (tourism and spa sectors) in difficulty, in the context of the Covid-19 emergency – Information to users on the protection of personal data

In order to disburse the regional bonus relating to the measure "Interventions to support people in difficulty", provided for by the Plan for the socio-economic emergency (approved with DGR - decree of the regional government - no. 170 of 7 April 2020), the Campania Region has established a collaboration relationship with INPS aimed at implementing the measures in compliance with the principles of cost-effectiveness, simplification, speed and efficiency.

In particular, pursuant to Articles 13 and 14 of EU Regulation 679/2016, the Campania Region and INPS inform users that the recipients of the support measures envisaged are identified by the Institute through the interconnection of its databases and that INPS disburses regional contributions to seasonal employees in the productive sectors of tourism and spas, residing in the Campania Region, who involuntarily terminated their employment in the period between 1 January 2019 and 17 March 2020 and who are not entitled to a direct pension benefit or, on 17 March 2020, had no employment relationship.

The processing of user data carried out by INPS as a result of the collaboration with the Campania Region does not cover the data included in the categories referred to in Articles 9 and 10 of EU Regulation 679/2016 and, in any case, is carried out by the Institute in compliance with the conditions and within the limits established by the same EU Regulation and by Legislative Decree no. 196 of 30 June 2003, as amended and supplemented by Legislative Decree no. 101 of 10 August 2018.

The processing of personal data takes place at INPS, using computerised, electronic and manual tools, with a logic that is strictly related to the purposes for which the information is collected and processed by the Institute, so as to ensure security and confidentiality (Articles 5 to 11 of the EU Regulation), and is carried out by specifically authorised and trained individuals who operate under the direct authority of the same Institute.

The exchange of data between the Campania Region and INPS will take place in a manner agreed between the parties that guarantees the adoption of adequate security measures (Article 32 of the EU Regulation), in compliance with the Provision of the Guarantor no. 393 of 2 July 2015, containing "Security measures and methods of exchanging personal data between Public Administrations".

Once the supplementary allowance has been paid, INPS will transmit to the Region the information certifying the payment of the supplementary allowance, making the data available in an anonymous and aggregate form for control and certification purposes.

The data necessary for disbursing the benefits will be processed by INPS in accordance with the law and, in any case, for a period not exceeding 10 years from the end of the disbursement itself, except for any disputes. This is without prejudice to the processing carried out for the purpose of archiving documentation in the public interest.

In the cases referred to in Articles 15 et seq. of the EU Regulation, data subjects have the right, at any time, to obtain confirmation of the existence of personal data concerning them and/or to verify the processing carried out by the data controllers. Data subjects, moreover, have the right to claim, in the forms provided for by the law, the rectification of inaccurate personal data and the completion of incomplete data; in the cases provided for by the EU Regulation, without prejudice to rules provided for certain processing, they may also claim the deletion of the data, after the prescribed storage periods, or the limitation of processing; opposition to processing, for reasons related to their particular situation, is allowed unless there are legitimate reasons for the continuation of processing. The appropriate request must be submitted:

• for INPS to the Data Protection Officer (INPS - Responsabile della Protezione dei dati personali, via Ciro il Grande, 21, postal code 00144, Rome; responsabileprotezionedati@inps.it; responsabileprotezionedati@postacert.inps.gov.it).

Data subjects who believe that the processing of their personal data carried out by data controllers is in violation of the provisions of the EU Regulation have the right to lodge a complaint with the Guarantor for the protection of personal data (National Supervisory Authority), or to take appropriate legal action (Articles 77 and 79 of the EU Regulation). Additional information regarding the rights of the data subjects can be found on the site of the Privacy Guarantor for the protection of personal data (www.garanteprivacy.it). Further information (Articles 13 and 14 of the EU Regulation) are prepared by INPS and the Campania Region and disseminated by the same data controllers through their respective institutional sites.