Green Pass Policy


This section contains information on the operational and organized procedures of MANIFATTURA FODERAMI CIMMINO SRL (VAT: IT 03552550638), with registered office in Via A. Depretis, 88 – 80133 NAPLES regarding the entry into force of decree 127 of 2021. This information is valid for the purposes of Article 13 of EU Regulation no. 2016/679, relating to the protection of individuals, for the verification of the green pass. in the workplace. Therefore, Manifattura Foderami Cimmino srl, as Data Controller, informs you, pursuant to art. 13 of EU Regulation 216/679, that the personal data provided will be processed with the following purposes and methods.

1. Interested

This information is directed to the following subjects whose personal data are processed: employees, collaborators, interns, volunteers, employees of external companies, temporary workers and all persons who access the company premises to carry out a work activity.

2. Purpose of the treatment

In order to prevent the contagion and spread of Covid-19 in the company, the Data Controller will verify the possession and validity of the Green Certification (Green Pass) pursuant to art. 5 n. 1 lett.B

3. Lawfulness of processing and legal basis

The legal basis of the processing is to be identified in the need to fulfill a legal obligation to which the owner is subject, pursuant to art. 6 lett. C and a 9 lett. B.

4. Processing methods

The treatment will be carried out by authorized and trained personnel and with a formal appointment. The verification activity must be carried out exclusively by scanning the QR code reported by the Green Certification through the use of the Verification C-19 application. The Green Certification must be shown to the personnel in charge in paper or digital form.

5. Personal data collected

The data controller processes (viewing and verifying) the personal identification data of the interested party resulting from the scan of the QR code (name and surname, date of birth and unique identification of the certificate), as well as the information relating to the negative outcome of the verification. , or the circumstance that the worker has declared to be or has been found to be without the green certificate. In the event of suspicion of the identity of the interested party, an identification document may be requested in a discretionary manner for a comparison with the data collected by scanning the QR code. We inform you that the verification of the certifications does not, in any case, involve the collection of the data of the holder in any form in compliance with the provisions of art. 13 paragraph of the Prime Ministerial Decree of 17 June 2021 – Implementing provisions of article 9, paragraph 10, of the decree-law of 22 April 2021, n. 52, containing “Urgent measures for the gradual resumption of economic and social activities in compliance with the need to contain the spread of the COVID-19 epidemic. quality of data controller. Data retention is determined by paragraph 1 of art. 16 of the Prime Ministerial Decree of 17 June 2021 and coincides with the period of validity of the certifications themselves.

6. Consequences in case of refusal to collect or supply data

In the case of refusal to exhibit the Green Certification both in paper and digital form or in the case of refusal to supply personal data, access to and permanence in the company premises is prohibited.

7. Recipients

The data may be known by those authorized for processing, by those designated for processing and, in particular, by the head of the personnel department in order to implement the provisions of the regulations. The data are not disclosed or communicated to third parties outside the specific regulatory provisions (eg in the event of a request by the investigating bodies for the demonstration of compliance with legal obligations). The data can be communicated to public authorities. The data is not transferred abroad and no automated profiling or decisions are made.

8. Conservation

The identification data and the negative outcome of the check (lack or invalidity of the Green Certification), which are recorded to document the reasons that prevented access to the company premises, are kept until the end of the state of emergency provided for by the public authorities competent. Retention for a longer period in relation to requests from the public authority is reserved.

9. Methods of protection

The interested parties have the right to obtain, in the cases provided for, access to their personal data and the correction or cancellation of the same or the limitation of the processing that concerns them or to oppose the processing (articles 15 et seq. Of the Regulation) . The specific request is submitted to the following addresses Interested parties who believe that the processing of personal data referred to them carried out in the manner indicated therein occurs in violation of the provisions of the Regulations have the right to lodge a complaint with the Guarantor, as required by art. 77 of the Regulation itself, or to take appropriate judicial offices (Article 79 of the Regulation). Furthermore, we inform you that the Data Controller is: Manifattura Foderami Cimmino srl, with registered office in via Agostino Depretis, 88 80133 Naples