{"id":2236,"date":"2023-10-17T06:50:03","date_gmt":"2023-10-17T06:50:03","guid":{"rendered":"https:\/\/movyonelectronics.com\/informativa-privacy-e-gestione-segnalazioni\/"},"modified":"2025-03-21T15:27:56","modified_gmt":"2025-03-21T15:27:56","slug":"privacy-policy-and-whistleblowing-report-management","status":"publish","type":"page","link":"https:\/\/movyonelectronics.com\/en\/privacy-policy-and-whistleblowing-report-management\/","title":{"rendered":"Privacy Policy and Whistleblowing Report Management"},"content":{"rendered":"\n
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Privacy Policy and Whistleblowing Report Management<\/a><\/h1>\n\n\n\n

Policy pursuant to Articles 13 and 14 of the European Regulation 2016\/679 on the Processing of Personal Data within the framework of the Whistleblowing System<\/p>\n<\/div><\/div>\n\n\n\n

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In implementation of the relevant legislation in force (Legislative Decree 24\/2023 – \u2018Implementation of Directive (EU) 2019\/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law and on provisions concerning the protection of persons reporting breaches of national laws\u2019)<\/em> Autostrade per l’Italia S. p.A. and the other Companies of Autostrade per l’Italia Group (listed in Annex 1 and hereafter jointly referred to as the \u2018Company\u2019 or the \u2018Data Controller\u2019) have implemented a system for the reception and management of reports of alleged unlawful acts, which allows the management of the report (\u2018Report\u2019) submitted by you to the Company through the Company’s specific dedicated channel. The system is designed for receiving and handling reports, including anonymous ones, sent to the Company by its staff and\/or third parties, and relating to potential breaches of national or European Union regulations, breaches of internal rules (rules of conduct set forth in the Code of Ethics, in the Anti-Bribery Guidelines, in the 231 Model and, more generally, in the corporate body of regulations), unlawful conduct and irregularities concerning the performance of Company activities. <\/p>\n\n\n\n

Pursuant to Articles 13 and 14 of the European Regulation 2016\/679 (hereinafter referred to as \u2018GDPR\u2019), each of the Companies listed above, as independent Data Controller, hereby provides information on the processing of personal data\/information (\u2018Data\u2019) concerning you (as a \u2018Whistleblower\u2019), acquired directly or indirectly, in relation to the \u2018Report\u2019 submitted by you, as well as on the processing of data\/information of the persons concerned by the Report itself (hereinafter also \u2018Whistleblowing Report\u2019). <\/p>\n\n\n\n

This Policy is hereby made available and accessible to potential data subjects through publication on the Controller’s institutional website. <\/p>\n\n\n\n

At its convenience, the Data Controller reserves the right to change, amend, add or delete any part of this Policy at any time. In order to facilitate the identification of any amendments, the date of revision will be indicated at the bottom of this Policy. <\/p>\n\n\n\n

1. DATA CONTROLLER<\/h3>\n\n\n\n

Autostrade per l’Italia, or any other Company of Autostrade per l’Italia Group to which the Report is submitted, shall be the independent Controller of the processing of your personal data, as Whistleblower, and\/or of the other parties involved in the Report for Whistleblowing management activities.

For more information on the Company acting as Data Controller for the Report you have submitted and on the Data Protection Officer (DPO) that each Data Controller has appointed, we kindly invite you to refer to Annex 1 of this Policy \u2018List of Data Controllers and Data Protection Officers (DPOs)\u2019 where you can find the addresses and contact details of the Data Controllers.

Should the Report, received through the \u2018internal reporting channel\u2019, fall under the responsibility of another Data Controller, it shall be addressed to the same by the competent Company acting as an independent Data Controller.<\/p>\n\n\n\n

2. TYPES OF DATA PROCESSED<\/h3>\n\n\n\n

In the context of the \u2018Whistleblowing\u2019 procedure, the personal data\/information subject to processing are the Data of the \u2018Whistleblower\u2019 (or \u2018Data Subject\u2019), of the \u2018Reported Party\u2019 and of the persons involved and\/or connected to the facts alleged in the ‘Whistleblowing Report’, such as, for instance, any witnesses (hereinafter, \u201cData Subjects\u201d).

Such Data, collected and processed by the Data Controller, include \u2018common\u2019 personal data of the Data Subject\/Whistleblower, of the Data Subjects (personal details, job position held in the Company, contact details such as: email address, postal address, telephone number), any other information contained in your Report, and, possibly, in some cases, where necessary, also data belonging to particular categories pursuant to Art. 9 GDPR or data relating to criminal convictions and offences under article 10 of the GDPR for the reasons of relevant public interest referred to in the Privacy Policy to the Whistleblowing Decree and, in any case, within the limits of the provisions of the relevant legislation, including articles 9 and 10 of the GDPR.

Data may be collected either directly from the Data Subject or through other parties involved in the Report, through the \u2018internal reporting channel\u2019 indicated above or through the other communication channels indicated in point 4 below.

The data are provided voluntarily by the Data Subject\/Whistleblower, also in anonymous form, to the Data Controller, who may not process data that are not strictly necessary for the purposes set out in point 3 below.

By way of example and without limitation, the \u2018Report\u2019 may be submitted by: employees of the Data Controller and\/or third parties who have a relationship with the Data Controller.<\/p>\n\n\n\n

3. PURPOSE AND LEGAL BASIS OF THE PROCESSING<\/h3>\n\n\n\n

Personal Data are processed exclusively for the purposes of investigating and verifying the facts alleged in the Report and adopting any consequential measures, in accordance with the provisions of Legislative Decree 24\/2023.

Specifically, the Personal Data collected are only those necessary and pertinent for the achievement of the purposes indicated above, on the basis of the \u2018principle of minimisation\u2019.

As far as these data are concerned, their provision is voluntary and the Data Subject is kindly invited to provide only the data necessary to describe the facts alleged in the Report without communicating personal data that are redundant and additional to those necessary for the purposes indicated above. Should they be provided, the Data Controller will refrain from using such Data and will delete them.

Personal Data are processed on the legal basis of the legal obligation, under article 6, par. 1 lett. b) (Legislative Decree 24\/2023 – Legislative Decree 231\/01), and of the legitimate interest of the Data Controller, under article 6, par. 1, lett. f) of the GDPR (provided that the interests or the fundamental rights and freedoms of the Data Subject do not prevail), to handle Reports of unlawful acts, of which the Whistleblower has become aware for professional reasons, within the context of their work or for other reasons, as well as to protect internal and external Data Subjects involved in the \u2018Whistleblowing\u2019 procedure.<\/p>\n\n\n\n

4. DATA PROCESSING METHODS<\/h3>\n\n\n\n

The data are collected in compliance with the regulations in force through computer-based, IT and manual tools, following procedures strictly related to the purposes indicated above, to guarantee the security and confidentiality of the data provided.<\/p>\n\n\n\n

More specifically, data are collected through the following computer-based\/IT tools:<\/p>\n\n\n\n