It was a fundamental commitment of the Comunicatorium to ensure the confidentiality, integrity, and privacy of the personal data of all natural and legal persons that in any way relate to it.
In strict compliance with the principles described in Regulation (EU) 2016/679 (General Regulation on Data Protection - RGPD), the Comunicatorium assumes to treat only the data that are strictly necessary for the development of the activity to be performed and its main objectives are to guarantee transparency in the processing of personal data and the exercise of the rights of data subjects, as well as to ensure the confidentiality, integrity, security and availability of the information it is dealing with and under its responsibility.
In the implementation of the RGPD, Comunicatorium, in order to fulfill its obligations, is guided by the principle of responsibility, namely:
- That the data is up-to-date, confidential and treated to ensure its safety;
- That the personal data processed are legitimate (principle of lawfulness) and are limited to what is necessary (principle of minimization);
- Which has policies, code of conduct and formalized procedures.
Considers it vital that data protection be provided from the outset and by default, that data security policies and procedures exist and that in the event of a breach, the controlling authority and the data subject are notified where applicable.
2. POLICY STATEMENT
Comunicatorium will take reasonable and proportionate measures to ensure that it protects personal data against improper, accidental or deliberate use, damage or destruction.
You are also committed to a policy of protecting the rights and freedoms of all individuals in relation to the processing of your personal data in accordance with data protection laws.
This policy applies regardless of where the personal data is held or whether it is performed manually or electronically.
The legal and proper treatment of personal information by the Comunicatorium is extremely important to the success of our business and to maintaining the trust of our clients and employees. Comunicatorium guarantees that it handles personal information legally and correctly.
3. POLICY RESPONSIBILITY
The Board of Comunicatorium has overall responsibility for ensuring that this policy complies with legal and ethical obligations and that all persons under its control practice it. It is also responsible for ensuring that all systems, services and equipment used to store data comply with acceptable safety standards.
All those working for or with Comunicatorium have a responsibility to ensure that data is collected, stored and handled appropriately. Each worker who deals with personal data ensures that they are treated and processed in accordance with the principles of this policy and data protection.
4. PRINCIPLES RELATING TO THE PROCESSING OF PERSONAL DATA
The processing of personal data carried out by Comunicatorium complies with the fundamental principles defined by the RGPD, characterized in the following figure:
5. COMPLY WITH THE POLICY
All Comunicatorium employees have read, understood and comply with this Policy.
Employees are responsible for ensuring that all personal data held by the Company in relation to their employment or position is accurate and up-to-date.
If you suspect that a violation of this policy has occurred or may occur, you should immediately notify your line Manager.
6. AVAILABILITY OF DATA FOR OTHER REASONS
In certain circumstances, the RGPD allows personal data to be disclosed to law enforcement agencies without the consent of the data subject.
In these circumstances, Comunicatorium will disclose the requested data. However, it will ensure that the request is legitimate, seeking advice from the legal adviser when necessary
7. RIGHTS OF PERSONAL DATA HOLDERS
Comunicatorium is committed to ensuring respect for the rights of the holders of personal data, namely the right of access and information, the right of rectification, the right to limit treatment, the right to portability, the right to be forgotten, the right withdrawal of consent, right of opposition, the right not to be subject to individual decisions taken in a fully automated manner, including the definition of profiles. The exercise of these rights is requested through the email address: firstname.lastname@example.org
All data subjects have the right to complain to the supervisory authority if they consider that the processing of their personal data violates the RGPD.
Applicants who have submitted a curriculum vitae or similar document also enjoy these rights. When giving this information to Comunicatorium, the candidates give their consent so that they are object of treatment in the Company.
Whenever the Comunicatorium uses subcontractors or third parties, they will be responsible for compliance with the RGPD and ensure that:
- the sharing of information and personal data comply with the requirements of the RGPD;
- the transmission of personal data is carried out safely;
- and are contractually bound to observe the obligations of confidentiality and secrecy and to ensure the security of personal data, which, for that purpose, are communicated to them, and may not use such data for any other purpose, for their own benefit or third parties , nor correlate them with other data that are in their availability.
8. COMMUNICATION AND CONSCIOUSNESS OF THIS POLICY
Awareness of this policy and the importance of complying with the main obligations of compliance with the RGPD is ensured by awareness raising actions for all workers.
9. USING THE COMMUNICATORIUM WEBSITE
Navigation data collected automatically (ie without registration) on the Comunicatorium site, are considered non-personal data because they do not allow identification of the holder. These data are used for statistical analysis in order to monitor the level of interest of the website and improve its performance and content adequacy.
10. INFORMATION COLLECTED ON THE WEBSITE
Comunicatorium only collects the information regarding the optional subscription of newsletters, or communications that fall within the scope of the communication consulting activity.
All data collected is stored centrally on your servers (platform name...)
The collection of data is the responsibility of the Comunicatorium that undertakes not to transmit information to third parties.
Our subscribers may at any time, change, delete the data they share with us.
Our newsletter submission platform, allows you to remove the subscriber, canceling the future reception of newsletters. If you wish to change and / or permanently delete your data from our platform as provided in the RGPD, please contact us at email@example.com
11. VIOLATIONS OF THIS POLICY
Compliance with the Policy set forth in this document is monitored by the Board of the Comunicatorium, eventually in conjunction with the Audit results.
Any employee who violates this policy will face the disciplinary measures provided for in the Company's Code of Conduct.
Comunicatorium may terminate your relationship with other individuals or organizations working on your behalf and in violation of this Policy.
12. SECURITY OF INFORMATION AND PERSONAL DATA
Comunicatorium has implemented appropriate technical and organizational measures to protect personal data in the field of logical security and physical security, in particular against accidental or unlawful destruction, accidental loss, tampering, unauthorized access and any other form of illicit treatment.
13. POLICY REVIEW
The Policy will be reviewed by management on a regular basis and may be amended whenever deemed necessary.
Date of last update: 27 of February, 2019