Institutional portal - Municipality of Milan

Information pursuant to articles. 13 and 14 of EU Regulation no. 2016/679

Pursuant to the articles. 13 and 14 of EU Regulation no. 2016/679 (General Regulation on the Protection of Personal Data), the following information is provided.

Data controller

The Data Controller with regards to the purpose that makes the collection, anonymization and storage of anonymous data necessary, is the Municipality of Milan with headquarters in Piazza della Scala, 2 – 20121 Milan – Technological and Digital Innovation Directorate, located in via G. Vico 18 – 20123 Milan – email address: ITeD@comune.milano.it 

Data Protection Officer (DPO)

The Municipality of Milan has appointed its own Personal Data Protection Officer who can be contacted at the e-mail address: dpo@comune.milano.it 

Purpose

The data processing is aimed at detecting the degree of citizen satisfaction with the city cleaning and waste collection services managed by Amsa Spa in 2023.

The survey will be carried out through telephone interviews with a representative sample of the adult population residing in the 40 neighborhoods of the city of Milan and in the operational areas in which the environmental hygiene service is divided. An online questionnaire will also be administered, sent to a panel (i.e. a group of people who have given consent to participate in surveys, research programs, market research) of Milanese citizens.

The carrying out of the investigation was commissioned to the company Demetra Opinioni.net SRL with registered office in Venice which was appropriately designated as Responsible for the Processing of personal data pursuant to Article 28 of the GDPR, and guarantees adequate technical security standards , and compliance with the principle of confidentiality referred to in the GDPR.

Legal basis

Personal data are processed in compliance with the conditions established by EU Regulation 2016/679 and in particular pursuant to the combined provisions of art. 6 – par. 1 letter e) and art. 2 ter of the Legislative Decree. 196/2003 “Code regarding the protection of personal data”, for the execution of a task of public interest or connected to the exercise of public powers in accordance with the law/Regulation vested in the data controller in accordance with the functions provided by:

- Legislative Decree 267/2000 Consolidated Law on the Regulation of Local Authorities, art. 147 Types of internal controls, letter e).

- the Directive of the President of the Council of Ministers of 27/01/1994 "principles on the provision of public services" and the Directive of the Minister of Public Function of 24/03/2004 "on the measurement of the quality perceived by citizens"

- The Legislative Decree 27 October 2009, n. 150 and subsequent amendments, art. 19 bis and art.28; Regulation on the internal control system of the Municipality of Milan (Deliberation of the City Council no. 7/2013 art.16).

Types of data processed

The personal data are of a common type and relate to natural persons of age who respond to the questionnaire required by the survey. In particular, the following will be processed:

- the landline or mobile phone number (only for the survey through telephone interviews)

- the email address (only for collection by completing the online questionnaire)

- the address of residence in order to determine the territorial area of ​​reference and the organizational unit into which the environmental hygiene service is divided

During the interview, you are also asked to indicate your age and whether you are an Italian or foreign citizen in order to guarantee the representativeness of the pre-established sample quotas, your educational qualification and your profession, both of which can be traced back to general categories (example employee, Manager/ Middle manager/managerial/technical, looking for work/unemployed, etc.)

The interviewee is in no way asked to indicate their name and surname.

Source from which the personal data originates

The personal data subject to the processing activity are acquired by the Demetra company, as owner of the activity as well as the maintenance and verification of the register. The procurement methods are as follows:

- landline telephone numbers are obtained from a public telephone directory in database format. This list is verified every fifteen days with the opposition register and the FUB (Ugo Bordoni Foundation) to exclude inadvertent contact with subjects registered in the register.

- mobile numbers are randomly generated (telephone operator roots + 4 previous contact numbers + 3 random numbers).

The company Demetra ordini.net Srl contacts the randomly generated number and asks the respondent to accept the use of the contact and to provide information on the municipality of residence. Furthermore, availability for participation in future surveys is requested and the interested parties are provided with information aimed at obtaining consent.

- The e-mail addresses of the citizens to whom the online questionnaire is sent are found within the database of members of the panel of which Demetra ordini.net Srl is the owner.

Mode of treatment

The processing takes place in compliance with fundamental rights and freedoms and is based on the principles of correctness, lawfulness, transparency and protection of confidentiality. It is also carried out with the aid of electronic instruments consistently with the operations indicated in the art. 4, point 2, of EU Regulation 2016/679.

The answers provided during the telephone interview and the completion of the online questionnaire cannot be linked to the telephone number, physical or e-mail address of the respondent as the software used manages them in separate databases; they are also processed anonymously and in aggregate form for statistical purposes.

Nature of treatment

Participation in the survey and therefore the response to the questionnaire is free and optional and any refusal does not entail any consequences. In case of participation, some answers to the questions in the questionnaire are necessary for the continuation of the interview which the interested party can interrupt at any time he deems appropriate.

Communication and dissemination

Personal data are not subject to communication or dissemination, except in cases where specific legal provisions provide for this last operation (e.g. judicial authority).

Personal data is not transferred outside the European Economic Area.

The results of the telephone survey will be made available in anonymous and aggregate form on the institutional websites of the Municipality and of the environmental hygiene service manager Amsa Spa; they will also be presented to interested parties and the main Consumer Associations for the purposes of continuous improvement of the services provided.

The results of the survey carried out using an online questionnaire are not disclosed externally but consulted by the offices concerned for research and in-depth purposes.

Categories of data recipients

The processing is carried out by authorized persons committed to confidentiality and responsible for the related activities in relation to the purposes pursued.

The data processing is also carried out by subjects external to the organization who assume the role of data controller pursuant to art. 28 of EU Regulation 2016/679 with respect to the general purpose of the activity of measuring the degree of citizen satisfaction:

- Demetra Opinioni.net SRL with registered office in Venice, via Piave, 96/98 with tax code and VAT number 03361530276;

It is specified that the company Demetra Opinioni.net SRL is the Data Controller with regards to the activity of retrieving and maintaining contacts.

The Owner and Manager art. 28 of the GDPR, guarantee:

- the implementation of adequate technical and organizational security measures, pursuant to art. 32 of the GDPR, including compliance with the principles of confidentiality;

- the legitimate acquisition of the availability of the information used to identify the telephone numbers necessary for the administration of the questionnaires

Data retention

The data will be kept for the time necessary to achieve the purposes for which they were collected and in any case for a maximum period of 2 years from the start of the surveys, after which the data will be eliminated. At the end of the surveys, the responses are delivered to the CRM Area in Excel format, in full and anonymized form

Data transfer to third countries

The data processed for the aforementioned purposes are not transferred to third countries outside the European Union or the European Economic Area (EEA) or to international organisations.

Rights of interested parties

Interested parties can exercise the rights provided for by the art. 15 and following of EU Regulation 2016/679 and in particular the right to access one's personal data, to request rectification or limitation, portability, updating if incomplete or incorrect and cancellation if the conditions exist as well as to oppose the Processing by addressing the request should be addressed to:

- to the Municipality of Milan as holder of the purpose of surveying the degree of citizen satisfaction, via G. Vico, n. 18 - 20123 Milan - Technological and Digital Innovation Directorate, located in via G. Vico 18 – 20123 Milan – email address: ITED@comune.milano.it 

or

- to the Personal Data Protection Officer of the Municipality of Milan (Data Protection Officer - “DPO”) who can be reached at the following e-mail address: dpo@Comune.Milano.it 

Right of complaint

Finally, we inform you that interested parties, if they believe that the processing of personal data relating to them occurs in violation of the provisions of EU Regulation 2016/679 (art. 77) have the right to lodge a complaint with the Guarantor, (www.garanteprivacy.it) or to take action in the appropriate judicial offices (art. 79 of the Regulation).

Modification

The Owner reserves the right to make to this Information, at its sole discretion and at any time, all changes deemed appropriate or made mandatory by the regulations in force from time to time, giving adequate publicity to interested parties.