Italian privacy regulations are based on the GDPR and the amended Privacy Code, and require each data controller to implement a minimum set of organizational, documentary, and technical measures proportionate to the risks of data processing.
Essential Regulatory Framework
The main reference is EU Regulation 2016/679 (GDPR), applicable in Italy since May 25, 2018.
In Italy, the GDPR is complemented by Legislative Decree 196/2003 as amended by Legislative Decree 101/2018, along with guidelines and provisions issued by the Data Protection Authority.
The competent supervisory authority is the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), which issues guidelines on DPIA, data breaches, processing registers, and related matters.
Basic Principles of Data Processing
Data must be processed lawfully, fairly, and transparently, for specific, explicit, and legitimate purposes.
- The principles of data minimization, accuracy, storage limitation, integrity, and confidentiality apply, along with the accountability of the data controller.
- The attached document explicitly refers to these principles, linking them to security policies and internal role organization.
Privacy Roles and Internal Organization
- At minimum, the following must be identified: Data Controller, any external Data Processor, authorized personnel, and third parties, as outlined in the organizational model.
- Where required by processing activities, a DPO (Data Protection Officer) must be appointed, with monitoring and advisory duties and acting as a contact point with the Authority. The DPO may be an internal employee or an external consultant appointed by the Controller or Processor.
- The document provides, among minimum internal obligations, the formalization of roles, instructions for authorized personnel, and regulations for the use of IT resources.
Minimum Documentary Requirements
- Preparation and updating of the record of processing activities (as Controller and, where applicable, as Processor), required for entities carrying out non-occasional processing and/or processing of special categories of data.
- Complete privacy notices to data subjects covering purposes, legal bases, retention periods, rights, possible transfers abroad, and contact details of the Controller/DPO.
- Contracts appointing external processors (Data Protection Agreements) and, where applicable, formal designation of system administrators.
Minimum Measures on Security, Data Breach, and Data Subject Rights
- Adoption of appropriate technical and organizational measures, including access control, password management, encryption where necessary, backup and disaster recovery, physical and network security, as listed in the model.
- Procedures for managing data breaches: incident analysis, risk assessment, notification to the Authority within 72 hours when required, and, in serious cases, communication to data subjects; establishment of a data breach register.
- Procedures for exercising GDPR rights (access, rectification, erasure, restriction, portability, objection) with dedicated contact channels, identity verification, and tracked management of requests.
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Teamiy Privacy: support@teamiy.com
Postal: Teamiy by TechVerdi, Avenue Charles-Ferdinand-Ramuz 60, 1009 Pully, Switzerland.