Information pursuant to article 13 of EU regulation 2016/679

Covid-19 green pass certification check

This information sheet provides information regarding the processing of your personal data and is formulated in accordance with the new GDPR legislation to promote full awareness of your rights (and duties) on the matter. More specifically it deals with: personal data acquired for the verification of the COVID-19 green pass, which is required to access the workplace in accordance with Article 9-septies of Italian Legislative Decree no. 52/2021, introduced by Article 3 of Legislative Decree 127/2021.

In order to manage the current state of emergency, ICAM Srl is required to comply with all the legal indications that make it possible to increase the effectiveness of the precautionary containment measures adopted to combat the COVID-19 epidemic. For this reason, starting on 15th October, 2021 and until such a time as the state of emergency ends, all personnel and suppliers who wish to access the company premises to carry out their work, including for training or voluntary activities on these premises, even if they have external contracts, will be obliged to be in possession of a COVID-19 green pass and show it upon request.

With regards to the protection of personal data and the current legislation, we remind you that checking your COVID-19 green pass constitutes the processing of your personal data.

The Data Controller is ICAM Srl with registered office at SP 237 delle Grotte, 70017 Putignano (BA) Italy, Tax Code no. 03685780722, Tel: +39 080 4911377, privacy@icamonline.eu

Personal data will be processed for the following reasons: 

  1. the purposes of preventing COVID-19 contagion, pursuant to Article 9-septies of Italian Legislative Decree no. 52/2021, as well as in order to check the authenticity, validity and integrity of the COVID-19 green pass or equivalent certification, including that of exemption from the anti-SARS-CoV-2 vaccination. The legal basis for this data processing comes from a legal obligation – the aforementioned Article 9-septies of Italian Legislative Decree no. 52/2021 – to which the Data Controller is subject. Therefore, pursuant to and for the purposes of Article 6, para 1, letter c) of the GDPR and for the particular categories of personal data covered by Article 9, para. 2, letter. b) of the GDPR, data processing for these purposes does not require the consent of the interested party; 
  2. in order to manage and carry out working relationships, as well as carrying out all the activities that are closely connected and instrumental to the management and execution of this working relationship. The legal basis for this data processing can be found in the execution of the employment contract, applicable to the interested party, and in the pursuit of the legitimate interests of the Data Controller in carrying out organizational activities, which are necessary and instrumental for the management and execution of the working relationship. Therefore, pursuant to and for the purposes of Article 6, para. 1, letter b) and letter f) of the GDPR, the processing of this data does not require the consent of the interested party. 

Furthermore, the Data Controller may process personal data to ascertain, exercise and defend their rights in judicial, administrative or arbitration and conciliation procedures. Treatment of the data is based on the legitimate interest of the Data Controller to safeguard their rights.

Within the limits of the purposes and methods defined in this information, the following data may be processed:

  1. the personal details of the employee, as well as the validity, integrity and authenticity of the green pass or equivalent certification or information regarding the status of anyone who is exempt from the COVID-19 vaccination as shown by the possession of a SARS-CoV-2 exemption certificate;
  2. the personal details of the employee and their failure to show a green pass. 

The personal data being processed applies to all of those who, for whatever reason, carry out work, training or voluntary activities on the ICAM Srl premises and includes those with external contracts, self-employed workers and associates who are not directly employed by the company.

It should be noted that for the staff of ICAM Srl, this information supplements that already provided for the processing of personal data necessary to establish and carry out their employment.

The provision of data is necessary in order to gain access to and remain in the workplace. Any refusal to grant data prevents the interested party from being given free access to the premises or continuing to remain there and may lead to sanctions according to the law (unjustified absence, administrative sanctions, and disciplinary sanctions as required).

Data processing is carried out by a verifier that ICAM Srl appoints, who acts according to specific instructions provided to them regarding the purposes and methods of data processing.

The COVID-19 green passes are verified exclusively using the Verification C19 App, by scanning the QR Code found on the green pass. Any equivalent certifications or exemption from SARS-CoV-2 certificates will be verified visually. 

At no time is the information relating to the certification and its holder acquired. Identification of the interested party, and a record of the outcome of the check, can only be made if it is necessary to document the reasons that prevented access to the workplace (e.g. a negative result) and to certify that checks have been carried out.

Personal data will be passed to the relevant company departments and to the Regional Prefect in the event of a violation ascertained within the workplace. For workers who operate under an external contract, personal data will be passed to the relevant employer, should the non-possession of a green pass be ascertained.

In any case the data will be processed strictly for the time necessary to pursue the aforementioned purpose of preventing the contagion of COVID-19, kept only for the statutory limited period, and used exclusively for purposes related to the fulfilment of legal obligations or to safeguard the rights of the Data Controller in court.

Interested parties have the right to ask the Data Controller for access to their personal data, and the correction or cancellation of this data, or to request a limit to the processing of data that concerns them. They can also oppose the processing of their data, without affecting any of their standard rights as per Articles 15-22 of the GDPR. Application for any of the above should be made to the following email address: privacy@icamonline.eu

The interested parties, having recourse to the above conditions, also have the right to lodge a complaint with the Guarantor in their role as supervisory authority in accordance with the established procedures. (www.garanteprivacy.it).

Body temperature screening and Covid-19 anti-contagion preventative measures

This information sheet contains essential information regarding the processing of your personal data and is formulated in accordance with the new GDPR legislation to promote full awareness of your rights (and duties) on the matter. More specifically it deals with: personal data relating to the screening of body temperature and the declaration which provides access to the workplace – anti Covid-19 legislation.

In order to manage the current state of emergency, ICAM Srl is required to comply with all the legal indications that make it possible to increase the effectiveness of the precautionary containment measures adopted to combat the COVID-19 epidemic. For this reason, any personnel or suppliers who require access to our premises for essential reasons, will only be able to access or remain in the workplace after having their body temperature checked and declaring if they have experienced any flu-like symptoms or been in contact with anyone who has tested positive for Covid in the 14 days prior to requesting access.

With regards to the protection of personal data and the current legislation, we remind you that any real-time body temperature screening and the collection of self-declarations constitute the processing of your personal data.

The Data Controller is ICAM Srl with registered office at SP 237 delle Grotte, 70017 Putignano (BA) Italy, Tax Code no. 03685780722, Tel: +39 080 4911377, privacy@icamonline.eu

The data will be processed for the purpose of preventing contagion from COVID-19 and safeguarding the health of the people who work in this company (in collaboration with the relevant public health authorities). The legal basis for this data processing is the execution of legal obligations, more specifically the implementation of the anti-contagion security protocols covered by the DPCM of 10 and 26 April 2020 (Shared Protocol 14 March and 24 April 2020).

More precisely, only data necessary for the prevention of COVID-19 infection will be collected. The provision of data is mandatory, pursuant to the current legislation on the containment of the risk of COVID-19 in accordance with national legislation, and any refusal to provide said data will result in access to the company premises being denied. The data will only involve the date, time, unique code, surname/name, contact details and result of the temperature screening (whether it complies, or is above 37.5°C and therefore non-compliant) without recording the actual temperature detected. In addition, information and declarations about the existence of any possible flu symptoms, (these checks may also be made visually if the symptoms have not been declared) or contact with people who have tested positive to Covid in the previous 14-day period will be acquired.

The data will be processed for as long as it may be necessary during the management of the current emergency. This is without prejudice to the retention of this personal data for a longer period, within the limits of the limited period, in order to respond to any possible requirements in the defence of rights in the event of disputes or requests from the public authorities.

Your temperature will be only be taken by personnel who have been specifically authorized to process this data and it will not be recorded, unless it becomes necessary to document the operation because of reasons which prevent access to the premises being given. 

The data relating to both the body temperature screening, and to any subsequent isolation measures, will not be communicated to anyone, apart from those we are obliged to inform in accordance with current legislation (e.g. in the event of a request by the Health Authority as they try to reconstruct and contact any “close contacts” or alternatively to the Civil Protection Authority or any medical professional in charge of the process).

Interested parties have the right to ask the Data Controller for access to their personal data, and the correction or cancellation of this data, or to request a limit to the processing of data that concerns them. They can also oppose the processing of their data, without affecting any of their standard rights as per Articles 15-22 of the GDPR. Application for any of the above should be made to the following email address: privacy@icamonline.eu

The interested parties, having recourse to the above conditions, also have the right to lodge a complaint with the Guarantor in their role as supervisory authority, in accordance with the established procedures. (www.garanteprivacy.it).