PERSONAL DATA PROCESSING POLICY NOTICE (REG EU 2016/679 and Italian privacy legislation), supplementing the Personal Data Processing Policy provided on the Accademia Teatro alla Scala website and applicable exclusively to the selection process for years 1–7 of the Academy Ballet School.

DATA CONTROLLER: Accademia d’Arti e Mestieri dello Spettacolo Teatro alla Scala (hereinafter “Academy”)
Registered Headquarters: Via Santa Marta 18, Milan, tel. (+39) 02-8545111, fax (+39) 02-86460020, email: privacy@accademialascala.it

 

LAWFULNESS AND PURPOSES OF PERSONAL DATA PROCESSING

  1. Videos for physical aptitude assessment of applicants for Course Level 1 and physical aptitude and technique assessment of applicants for Course Levels 2 and 3 as specified in the Academy Ballet School course announcement and further supplements. The videos supplement personal data that are collected during the application process and necessary for enrollment of applicants who pass the selection process;
  2. (Only for applicants summoned physically to Academy facilities) Prevention of COVID-19 contagion among auditioning applicants who access Academy facilities in compliance with national and regional protocols and regulations and with the latest available version of the Annex to the Academy Risk Assessment Document for the COVID-19 emergency and associated protocols. The following personal data will be processed for this purpose:
  • Communication regarding the absence of COVID-19 contagion, any triage medical exams, and assessment of COVID-19 impact;
  • COVID-19 blood tests (required by Academy physician for applicants to Course Levels 1–3; voluntary or requested by Academy physician for applicants to Course Levels 4–7) and throat swabs (obligatory following a positive COVID-19 blood test);

Body temperature checks at the entrance.

 

PERSONAL DATA STORAGE PERIOD

The personal data storage period depends on legislation in force to safeguard the rights of the Data Subject and the Data Controller, and for the purposes of maintaining a historical archive.

Personal data storage times and criteria are documented in detail in the personal data processing registry of the Academy; specific times will be communicated to Data Subject per request. The request must be sent to privacy@accademialascala.it. Access to these data is subject to an assessment of the legitimacy of the request.

 

PERSONAL DATA SUBJECT TO PROCESSING AND METHOD OF PROCESSING

In processing personal data that may be used to identify the Data Subject either directly or indirectly, the Academy shall adhere to the principle of strict necessity and seek to ensure the confidentiality of the processed data. We shall thus collect and provide to the data recipients, subjects authorized to process said data, and third parties where applicable (see “Data Recipients and Subjects Authorized to Process Personal Data” below) only those data necessary for accomplishing the above-specified purposes. Personal data will be processed in computerized form by Academy offices and the Academy Dance Department using methods and within the limits necessary for accomplishing said purposes. No sensitive data is requested as relates to the purpose stated above. Further information on this point may be requested by writing an email to relazioni.esterne@accademialascala.it.

 

DATA PROVISION REQUIREMENT

The provision of personal data is necessary for accomplishing the purposes set forth above. Specifically:

  • Purpose a) the provision of personal data for the above purpose is necessary in order to assess the eligibility of the applicant to be included in the selection process as described in the relevant course announcement and associated updates, as indicated above under “Lawfulness and Purposes of Personal Data Processing”;

Purpose b) the provision of personal data is necessary as regards possible physical presence of the applicant at Academy facilities for evaluation as indicated above under “Lawfulness and Purposes of Personal Data Processing”, while as regards purpose b2, blood tests are obligatory for Course Levels 1–3, optional or ordered by the Academy physician for Course Levels 4–7, whereas throat swabs for all course levels (1–7) are obligatory only in the event of a positive COVID-19 blood test, as indicated above under “Lawfulness and Purposes of Personal Data Processing”.

 

LEGAL BASIS FOR PERSONAL DATA PROCESSING

The legal basis for personal data processing regarding:

Purpose a) the legitimate interest of the Academy to fulfill its charter and provide the services implicit therein and to comply with national and regional legislation regarding the management and administration of educational programs (including internships and practicums) and career services, contract law, and associated applicable legislation;

Purpose b)  general workplace health and safety principles: Italian Civil Code Article 2087; Italian Legislative Decree no. 81/08 on workplace health and safety; Regulation (EU) 2016/679 (General Data Protection Regulation) Article 6, Paragraph 1, Letters (c) [compliance with a legal obligation to which the controller is subject] and (d) [protection of the vital interests of Data Subject or other natural person, such as visitors to the Academy] and Article 9, Paragraph 2, Letter (b) [obligations and specific rights of the controller or of the data subject in the field of employment and social security and social protection law]. Anti-contagion safety protocols (Art. 1, Paragraph 7, Letter d of DPCM 11/3/2020) and subsequent national or regional protocols or regulations. The measures are listed in the “Annex to the Academy Risk Assessment Document for the COVID-19 Emergency” and in the most recent associated protocols, which have been developed accounting for recommendations by the Italian Sports Physicians Federation (Federazione Medici Sportivi Italiani – FMSI) regarding the resumption of sports activities.

 

DATA RECIPIENTS AND SUBJECTS AUTHORIZED TO PROCESS PERSONAL DATA

Purpose a) The following parties may have access to Data Subject videos: Academy personnel (employees, collaborators, authorized professionals) for organizational purposes, and members of selection committees.

Purposes a) and b) Personal data, including that of a sensitive nature, provided by applicants to the Ballet School as required by the selection process as described in the course announcement and subsequent revisions may also be processed by:

  • authorized Academy personnel in the performance of assigned duties as regards the purposes listed above;
  • specialized medical personnel authorized by the Academy to carry out medical evaluations, including the Academy Physician (who is the only subject authorized to process personal data regarding the communication demonstrating an absence of COVID-19 infection and any medical triage).

Furthermore, again regarding Purposes a) and b), certain third parties, who may provide services on an outsourcing basis, are specifically charged with operating and maintaining information systems used to process Data Subject personal data. As a result, said data may be processed by personnel of these third parties acting as external data processors on behalf of the Academy and/or as system administrators, if so named, and applying appropriate measures to ensure data confidentiality and protection.

Personal data may also be processed by public safety authorities, judicial authorities (on specific request), and other agencies legally authorized to receive such data.

The list of external parties who process personal data on behalf of the Data Controller (the Academy) is available upon request from privacy@accademialascala.it. Access to this list is provided only to those parties whose request is deemed to be legitimate by the Data Controller.

 

SECURITY OF DATA

Data Subject personal data deriving from the videos will be processed using automatic tools in keeping with the principle of necessity and proportionality, avoiding processing of personal data when the operations can be carried out using anonymous data or in other ways. The Academy has implemented specific security measures to prevent loss of personal data, illicit or improper use of personal data, and unauthorized access to personal data.

 

DATA TRANSFER

The personal data addressed in this privacy policy notice are processed exclusively within the European Economic Area.

 

DATA SUBJECT’S RIGHTS

By contacting the Data Controller via the Company Privacy Policy Contact at privacy@accademialascala.it, the Data Subject may exercise applicable rights as regards his or her personal data, including deletion of personal data, correction of inexact data, addition of missing data, limitations to processing, data portability, or objection to data processing without adversely affecting the rights and freedoms of the Data Controller.

The Data Subject’s consent to processing his or her personal data for any of the purposes indicated herein may be withdrawn at any time.

The Data Subject has the right to lodge a complaint with a supervisory authority in the EU member state where the Data Subject maintains his or her principal residence or in the state in which the presumed violation occurred. Further information on the Data Subject’s right to lodge a complaint may be found at: https://goo.gl/GLbTN9. The Data Subject will not be subject to a decision based solely on automated processing or profiling. 

 

ACADEMY PRIVACY POLICY CONTACT

For clarifications, information, exercise of Data Subject’s rights, or other requests, contact the Academy Privacy Policy Contact at: privacy@accademialascala.it 

 

ACADEMY DATA PROTECTION OFFICER

In order to ensure the security of Data Subject’s personal data and observance of Data Subject’s rights, the Academy has appointed a Data Protection Officer having support, oversight, consultancy, instructional, and informational functions, cooperating and acting as liaison with the Italian Data Protection Authority for issues relating to personal data processing. The Academy Data Protection Officer may be contacted at: dpo@accademialascala.it 

In order to ensure the security of Data Subject’s personal data and observance of Data Subject’s rights, the Academy has appointed a Data Protection Officer having support, oversight, consultancy, instructional, and informational functions, cooperating and acting as liaison with the Italian Data Protection Authority for issues relating to personal data processing. The Academy Data Protection Officer may be contacted at: dpo@accademialascala.it

 

Rev. June 10, 2020