Personal Data Protection Policy
(Pursuant to Art. 13 of European Regulation no. 679/2016)
Before acquiring your personal data for the management of the claim, Trenitalia S.p.A. invites you to carefully read the Personal Data Protection Policy.
I. Data Controller and Data Protection Officer
This section provides details on our contact details
• Data Controller: Trenitalia S.p.A. represented by the pro-tempore CEO, who can be contacted via email@example.com, with registered office in Piazza della Croce Rossa 1 – Rome.
• DPO: Data Protection Officer contact details: firstname.lastname@example.org
II. Types of personal data
This section outlines the types of data requested from you
The personal data being processed falls into the following categories:
Personal data of the complainant/user:
• Common data of the person filing the report: personal data (name, surname, address,), contact details (email).
• Common data of the user (if different from the complainant) and of any other passengers: personal data (name and surname), copy of their identity document
• Optional data – Telephone contacts, FRECCIA card number.
• Optional data: Telephone contacts, FRECCIA card number.
• Special Data: based on the nature of the claim submitted by you, Trenitalia may become aware of data belonging to so-called “special” categories of data (for example, data pertaining to health). In consideration of the fact that this data has been made available to Trenitalia manifestly and freely, no explicit consent is required for handling the procedure. Trenitalia assures you that such data will be processed exclusively for purposes strictly connected and instrumental to the management of the procedure itself. In the absence of such personal data, Trenitalia will not be able to partially or totally follow up with your request.
The data will be processed by computer and on paper so as to ensure appropriate security and confidentiality measures.
III. Processing Purposes
This section covers the scope of the processing carried out on your data
a. Handling of complaint procedure (legal basis: Contractual)
b. Transmission of the complaint also containing any particular data to the competent managers (legal basis: Legal – Measure 5.2, Annex A to the Transport Regulatory Authority Resolution 28/2021 and Article 9, paragraph 2(G) of the GDPR)
c. Improvement to the management of complaints in the event of communication difficulties and/or to hasten the response times by means of the telephone contact data provided by the data subject (legal basis: Consent)
The provision of the data necessary for the pursuit of the purposes referred to in Points a) and b) is Mandatory, hence your refusal shall render it impossible for Trenitalia S.p.A. to manage the request.
The provision of the data necessary for proceeding with the purpose referred to in Point c) is Optional, hence failure to provide such shall exclusively render it impossible for Trenitalia S.p.A. to improve the management of the request in the event of communication difficulties and/or to ensure faster response times.
Any granted consent is freely revocable at any time, without prejudice to the lawfulness of the processing carried out prior to the revocation. The withdrawal of consent may be communicated by contacting the Data Protection Officer via the email address: email@example.com.
IV. The data recipients
This section outlines who will process your data and to whom it will be communicated
For the pursuit of the aforementioned purposes, the personal data will be processed by the following subjects:
Subjects connected to Trenitalia S.p.A.:
• Persons authorised to carry out the processing (employees of Trenitalia S.p.A.)
• Computer service companies
• Other FS Group companies
Subjects not directly connected to Trenitalia S.p.A.:
• Insurance service companies
• Other railway or transport companies to which the complaint shall be transmitted if the subject of the complaint is within their competence – these companies shall process the aforementioned claim as independent Data Controllers
• The Transport Regulation Authority
• Judicial authorities
• Public safety authorities
Your data will be processed only by persons expressly authorised by Trenitalia S.p.A. or by companies acting as Data Processors on behalf of Trenitalia S.p.A. who have signed a special contract that specifically regulates the processing entrusted to such parties and the obligations regarding the protection of the data, which will never be disseminated.
Your personal data may also be transmitted to other independent Data Controllers or joint Data Controllers on the basis of law or regulation, in accordance with the specific consent provided by you. The updated list of data recipients is available by contacting the Data Protection Officer via the email address: firstname.lastname@example.org.
V. Data Retention
This section covers the amount of time your data is retained
The personal data you have provided to us shall be retained for 10 years from the conclusion of the complaint.
This is without prejudice to additional retention for the following purposes: archiving in the public interest, scientific or historical research, statistical purposes or technical reasons (such as business continuity).
VI. The Data Subjects’ Rights
This section provides details on your guaranteed rights
EU Regulation 2016/679 (Articles 15 to 23) grants Data Subjects the exercise of specific rights. In particular, in relation to personal data processing, the Data Subjects have the right to ask Trenitalia S.p.A. for access and opposition to and the correction, rectification, erasure, limitation and portability of the data. In addition, they may lodge a claim with the Supervisory Authority, which in Italy is the Data Protection Authority.
You may request to exercise your rights before Trenitalia S.p.A. at any time by contacting the Data Protection Officer at the e-mail address: email@example.com.