Privacy Policy – Final questionnaire

Pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”), the AlmaLaurea Interuniversity Consortium informs graduates, master’s graduates and PhD holders (hereinafter “data subjects”) of the purposes and methods by which their personal data are processed by the Consortium as an independent data controller, noting that the same data are also processed by their university, higher education school, AFAM institution or ITS institution.

Data controller and Data Protection Officer:

Purpose of the processing of personal information:

  • Within the scope of its institutional purposes and in its capacity as a member of SISTAN (National Statistical System), AlmaLaurea will process the personal data provided by data subjects in completing the optional questionnaire for the following purposes:
    1. Preparation of statistical reports relating to the final questionnaire. Note that the data provided when completing the questionnaire will also be processed in the context of other subsequent surveys, in compliance with the data retention period indicated below.
    2. [graduates only] To support graduates’ entry into the labour market and their professional training, by including the data collected through the questionnaire in the curriculum vitae in the AlmaLaurea database, where the graduate has previously consented to its creation. The various sections of the questionnaire highlight which data are processed for the purposes of preparing statistical reports and which data can also be processed for the purpose of facilitating entry into the labour market and professional training through their inclusion in the curriculum vitae (information on one’s high school diploma, language skills, computer skills, experience abroad, internships, intention to continue studies, characteristics of the job sought).
    3. [graduates only] Conduct statistical research on elementary data stripped of direct identifiers within the framework of the Consortium's institutional purposes and in compliance with the Guidelines for access for scientific purposes to elementary data of the National Statistical System.
    4. Make available or provide access to the personal data, even in identifiable form, to public or private parties that are authorised to make such a request by virtue of a provision of law, regulation or a general administrative act.

Legal bases for the processing of personal data:

  • For the purpose referred to under letter a) of the “Purposes” section (preparation of statistical reports, including as part of subsequent surveys), the data provided by data subjects are processed only where they give their consent, pursuant to art. 6, paragraph 1, letter a), of Regulation (EU) 2016/679.
  • [graduates only] For the purpose referred to in letter b) of the "Purposes" section (facilitating entry into the labour market and professional training), the data provided by data subjects, and thus included in the curriculum vitae created by them, will only be processed if they give their consent pursuant to Art. 6, paragraph 1, letter a), of Regulation (EU) 2016/679.
  • [graduates only] For the purpose referred to in letter c) of the "Purposes" section (statistical research on elementary data as part of the Consortium's institutional purposes), the data provided by the data subjects, stripped of direct identifiers, may be processed by the Consortium for further statistical research purposes by virtue of the Consortium's legitimate interest in research, as well as in the promotion and performance of scientific research initiatives and activities as envisaged by the institutional purposes of AlmaLaurea, pursuant to art. 6, paragraph 1, letter f), of Regulation (EU) no. 679/2016, its Articles of Association and the Rules approved by the Board of Directors in session no. 69 of 05/12/2022, which can be found at: https://www.almalaurea.it/trasparenza/disposizioni-generali. The Consortium specifies that this processing may entail access to the data by parties outside the Consortium, as further specified below in the paragraph “Recipients or categories of recipients of the personal data”. However, access to the personal data without direct identifiers shall take place in a secure and predetermined manner as described in the aforementioned Rules, and the data subjects shall always have the right to object to the processing according to the methods outlined in the paragraph below, "Exercise of the data subject's rights".
  • For the purpose set out in letter d) of the "Purposes" section (disclosure of data required by law), the data provided by the data subjects may be disclosed in order to fulfil a legal obligation that the Consortium is subject to pursuant to art. 6, paragraph 1, letter c), of Regulation (EU) 2016/679.
  • The Consortium notes that, with regard to the purposes set out above under letters a) and b) [letter b) applies only to graduates], any failure to provide the data, failure to obtain consent or subsequent withdrawal of consent to the processing of the data will not have any consequences with respect to the data subjects’ relationship with AlmaLaurea and with the university, higher education school, AFAM institution or ITS institution they belong to.
  • Note also that, for the purposes of any processing done based on consent, the data subjects have the right to withdraw such consent at any time without such withdrawal affecting any processing done prior to withdrawal.

Retention of the data provided:

  • In light of the institutional purposes under letter a) of the "Purposes" section (preparation of statistical reports, including as part of subsequent surveys), in particular with regard to the promotion and performance of scientific research, also as a member of SISTAN, taking into account the need to monitor the evolution of one’s occupational condition over the long term, the personal data provided will be stored for 30 years, while [graduates only] for the purposes under letter b) of the "Purposes" section (facilitating entry into the labour market and professional training) they will be retained as long as the user keeps their profile (Curriculum Vitae) active on the AlmaLaurea portal, and in any case where consent is never withdrawn.
  • [graduates only] For the other purposes referred to in letter c) of the "Purposes" section (statistical research on elementary data as part of the Consortium's institutional purposes) pursued on the basis of the Consortium's legitimate interest and in compliance with the Guidelines for access for scientific purposes to elementary data of the National Statistical System, the personal data shall be kept for 30 years unless the data subject otherwise objects.
  • For the pursuit of the purpose referred to in letter d) of the “Purposes” section (disclosure of data required by law), the personal data will be processed only for the time necessary to comply with the obligation to disclose them.
  • The data are stored and protected with appropriate security measures. In particular, the data are stored in a pseudonymised form, implementing mechanisms of logical and/or physical separation between the data provided in response to the questions in this questionnaire and personal and contact data. After the aforementioned retention periods have expired, the personal data shall be destroyed or irreversibly anonymised.

Recipients or categories of recipients of personal data:

  • For the purpose referred to in letters a) and b) [letter b) applies only to graduates] of the "Purposes" section (preparation of statistical reports also through questionnaires and other surveys and facilitating entry into the labour market and professional training), the data provided in this questionnaire may be accessed by the following parties or categories of parties: the relevant university, higher education school, AFAM institution or ITS institution in question, in their capacity as autonomous data controllers, if they are members of the Consortium, or if they have entered into specific agreements therewith, and which can be consulted at the following link www.almalaurea.it/info/chisiamo/chisiamo_soci, on whose behalf the processing is carried out by the Consortium as data processor.
  • [graduates only] For the purpose referred to in letter c) of the "Purposes" section (statistical research on elementary data as part of the Consortium's institutional purposes), the personal data, stripped of direct identifiers, may be accessed by recognised research bodies and institutes, the list of which may be consulted at https://www.sistan.it/index.php?id=650, or by other entities belonging to SISTAN, as autonomous data controllers, subject to approval of the research project.
  • For the purpose referred to in letter d) of the "Purposes" section (disclosure of data required by law), the personal data may be made available to or be accessed by the Administrations and institutional and private bodies authorised by law, regulation or general administrative act to access the AlmaLaurea database, including by way of example the National Agency for the Evaluation of the University and Research System ("ANVUR").
  • The personal data may be disclosed to the employees and contractors the Consortium works with in the performance of its activities, specifically designated as persons authorised to process data, as well as to the persons appointed by the Consortium to provide technical support and services in support of the survey, in their capacity as data processors pursuant to art. 28 of the GDPR, the list of which is available upon request.
  • In any case, any publication and dissemination of the data collected for statistical purposes shall take place exclusively in an anonymous and aggregated form. Under no circumstances shall it therefore be possible to trace the identity of the data subjects.

Rights of data subjects:

  • The data subject can exercise the rights granted to them by current legislation on the protection of personal data, including the right to ask the data controller to access their personal data and to correct or erase them, restrict or object to processing of their data, in addition to the right of data portability within the limits of the provisions of articles 15-21 of Regulation 2016/679.
  • Specifically, with regard to the right of objection set out in Article 21, the data subject may exercise this right in order to obtain the exclusion of their record from the elementary data used in the specific research project by sending a communication to the User Support Office at the following address: supporto.laureati@almalaurea.it.
  • To exercise their rights, including the right to object and to withdraw consent, the data subject may contact the data controller by sending a communication to the User Support Office at the following address: supporto.laureati@almalaurea.it.
  • Pursuant to art. 77 of the Regulation, if the data subject believes that the processing of their data violates the legislation on the protection of personal data, they have the right to lodge a complaint with the Italian Data Protection Authority or the control authority of the EU Member State in which you usually reside, work or the place where the alleged violation occurred.