Privacy Policy


Attachment relating to the processing of data relating to activities to combat Covid-19”


Last Update 15/07/2020




Holder of the Treatment:

- Antoniano S.r.l., Italian company based in Via Fasolo 12, 35036 Montegrotto Terme (Padova).



-Employees, collaborators, suppliers, visitors, customers, people who have access to company premises.


Legal Basis:

- Grounds of public interest: implementation of the anti-contagion safety protocols in accordance with the article 1, n.7 lett.d, of the DPCM 11 March 2020, in particular shared Protocol 14 March 2020, Protocol 24 April 2020, and subsequent integration and amendments.

- Obligation to read: article. 32 of the Constitution; art. 2087 c.c.; d.lgs. 81/2008 (in particular art. 20).


Purpose of the treatment:

- prevention of covid-19 infection.

- protection of the health of people in the company

- collaboration with public authorities and, in particular, the health authorities.


Data collection:

1. Body temperature detection in real time, without registration or conversation, except for the hypothesis set out in the following n.2;

2. Identification data and recording of exceeding the temperature threshold only if it is necessary to document the reason that prevents the access to the company premises or their permanence; as well as, in the case, the recording of data relating to temporary insulation, such as the exit time and circumstances referred to by the interested party as justification for leaving the temporary insulation.

3. Situation of danger of contagion from covid-19, including data relating to the state of health, such as, for example, body temperature/flu symptoms; origin/non origin from the areas at epidemiological risk; presence/absence of contacts, in the last 14 days, with subjects having tested positive covid-19.

4. Health status data regarding the negative effects of the covid-19 swab ( test )

5. Situations of particular fragility and current or previous employee pathologies.


Consequences in case of refusal to collect data:

- In the case of refusal of temperature detection or data supply, access to company premises and their permanence are prohibited.



- The data can be known by authorized to the treatment; from designated to processing and in particular by the head of the personnel office; by the competent doctor.

- The data are not disclosed or communicated to the third parties outside the specific regulatory provisions ( ex. in the event of a request by the Health Authority for the reconstruction of the supply chain of any close contacts of a worker tested positive to covid-19 ). The data can be communicated to public authorities.

- The data are not transferred abroad and no automatic profiling or decisions are made.


Conversation period:

- The identification data at the exceeding of the temperature threshold, recorded only if it is necessary to document the reasons the prevented access to the company premises, as well as information relating to temporary insulation are kept until the end of the state of emergency envisaged by the competent public authority. No recording and/or conversation is carried out on the event of failure to exceed the temperature threshold.

- The conversation is reserved for a longer period in relation to a request from the public authority.

- The conversation of personal data, even particular, for a longer period, subject to the limitation period of the rights, in relation to needs related to the army of the rights of defense in case of disputes is reserved.


Protection method:

- The interested parties have the right to obtain, in the cases provided, access to their data and the correction or cancellation of the same or the limitation of the processing that concerns them or to oppose the processing (artt. 15 e ss. of the following Regulation). The appropriate application is presented at the following addresses

- Interested parties who believe that the processing data referred to them carried out in the manner indicated therein occurs in violation the the Regulation have the right to lodge complaint with the Guarantor, as provided for in Article 77 of the Regulation itself, or to bring the appropriate judicial offices ( article 79 of the Regulation )


Contact details of the Data Protection Officer:

- The Data Protection Officer can be contacted at the following addresses:

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