Virtual Café - NEOLAiA
Information on Data Processing
The legislation and the regulations on the protection of personal data require us to inform you about the
processing of your data as a student or professor of the NEOLAiA Alliance of European Universities.
The processing will be based on the principles of legality, fairness and transparency to guarantee the
protection of your personal data (integrity and confidentiality), including protection against unauthorised or
unlawful processing and accidental loss, destruction or damage, by implementing appropriate technical and
organisational measures.
Date: 29/05/2024
1. Name of the service
Virtual Café – NEOLAiA
2. Description of the service
The virtual cafés are intended to serve as informal, online meeting spaces where members can gather to
share ideas, network, and collaborate in a relaxed, casual environment. These virtual café provide a space
for spontaneous interactions, fostering deeper connections and more dynamic exchanges among community
members. The platform we have chosen to use as the Virtual Café for NEOLAiA is Discourse. Discourse is a
powerful, open-source platform designed for online discussions and community engagement. We will use
this platform to engage and empower the communities within and around NEOLAiA. Initially, this space will
be dedicated to researchers, university staff and academics, who will be grouped into "communities of
interest" based on topics, functions, or categories. The platform allows also the management through
community moderation, if needed. This can be exploited by encouraging users to take responsibility for the
space by rewarding their involvement and contributions to community upkeep.
3. Data Controller and Data Protection Officer
The Data Controller is the University of Salerno with registered office in Via Giovanni Paolo II, 132 - 84084 Fisciano (SA).
The University of Salerno has also appointed a Data Protection Officer.
In any case, communications to the Data Protection Officer should be sent by e-mail to the following
addresses:
4. Purpose and duration of the processing and legal basis
The processing involves recording the following personal data on digital forms:
- For all users visiting the webpage:
- IP address
- Referrer address
- For authenticated users, the following data are retrieved from the organisation:
- Common name - used to configure the user logged into the system;
- pairwise-id - used as the identifier for the user in the Discourse Database
- NameID (persistent) - used as the identifier for the user in the Discourse Database;
- eduPersonTargetedID - used as the identifier for the user in the Discourse Database
- Affiliation (eduPersonScopedAffiliation) - used to create user-based groups;
- E-mail - used for registration and authentication on the platform under consideration.
Currently 3 different identifiers are required, but only one will be used. If available, pairwise-id is used, otherwise NameID:persistent or as a last chance eduPersonTargetedID. This is because NameID:persistent and eduPersonTargetedID will soon be dropped, so this is a temporary solution until all Identity Providers migrate to pairwise-id.
The following data are stored on well protected servers.
No further data or data concerning health and, in general, special categories of personal data referred to in
articles 9 and 10 of the General Data Protection Regulation EU 2016/679, “Privacy Regulation” (i.e.: data
concerning health, data relating to criminal convictions and offences etc.) are processed.
The purposes of the processing are the organisational needs related to the use of the “Virtual Café” service
of the NEOLAiA Project - Transforming Regions for an Inclusive Europe - funded under the ERASMUS-EDU-
2023-EUR-UNIV - Partnerships for Excellence - European Universities Programme.
Only specially authorised personnel may access the data.
The University of Salerno will keep your data for the period necessary to fulfil the purposes for which they
were collected.
Personal data, IP address and Referrer address are stored only in the logs created by the web server and the
Shibboleth software. Logs will be stored for 6 months and will be automatically deleted after this period.
5. Disclosure to third parties and transfer to third countries
In order to carry out some of the activities related to the processing of your personal data, the University of
Salerno may disclose part of your data to external companies entrusted with services related to the particular
case.
In addition to the people in charge of processing, employees and collaborators of the Controller specifically
authorised for this purpose may gain knowledge of the personal data.
These people will act as Data Processors or Authorised Processors.
Personal data may be disclosed to other public and/or private entities solely by virtue of a provision of law
or regulation that so provides. The data may also be passed on to subjects, bodies or authorities to whom
the communication of the data is obligatory by law or in order to comply with orders from the Authorities.
Data will not be further processed and will not be transferred to countries outside the European Union.
6. Rights of the data subject
We remind you that the legislation grants you certain rights. In particular:
- The right to obtain confirmation of the existence or non-existence of data concerning you and
receive notification thereof;
- The right to know the origin of the data, the purposes of the processing and its methods, as well as
the logic applied to the processing carried out using electronic means;
- The right to request that the data be updated, rectified or if you have an interest, completed;
- The right to obtain their erasure (right to be forgotten), their transformation into anonymous form
or blocking, as well as the right to object to their processing for legitimate reasons.
Moreover, the Privacy Regulation has introduced new rights that you may exercise (where applicable),
namely:
- The data subject shall have the right to withdraw his or her consent at any time. The withdrawal of
consent shall not affect the lawfulness of processing based on consent before its withdrawal, with
the express warning that the data will be stored for a maximum of 5 further days;
- The data subject shall have the right to object at any time to processing of personal data for the
purposes of legitimate interest;
- The data subject shall have the right to obtain the portability of personal data concerning
himself/herself;
- The data subject shall have the right to lodge a complaint with the Data Protection Supervisor if the
conditions are met;
- The data subject shall have the right to request the restriction of the processing of personal data in
the event that:
- the accuracy of the personal data is contested by the data subject, for a period enabling the
controller to verify the accuracy of the personal data;
- the processing is unlawful and the data subject opposes the erasure of the personal data
and requests the restriction of their use instead;
- the University of Salerno no longer needs the personal data for the purposes of the
processing, but they are required by the University of Salerno for the establishment,
exercise or defence of legal claims;
- the data subject has objected to the processing pursuant to Article 21(1) of the Privacy
Regulation pending the verification whether the legitimate grounds of the controller
override those of the user.
You may at any time exercise the above rights or obtain further information on the use of your personal data
by the University of Salerno by contacting the e-mail address indicated in the paragraph “Data Controller and
Data Protection Officer”.
7. Cookies Policy
Information that may relate to the user, their preferences or their Internet access device (e.g. computer,
tablet or mobile phone) is collected on the site and is used mainly to adapt the operation of the site to the
user’s expectations, providing a better browsing experience.
The following categories of cookies are used for the site and other online services:
-
Essential cookies: these cookies are necessary for the proper functioning of the website and to use
and/or improve the various functions and/or services requested. Without these cookies, it is not
possible to manage and automate, for example, user authentication and/or access to the private
area of the website.
The Virtual Café service (based on the open source Discourse software) by default sets cookies that are
essential for its basic functionality for the communication between people and for publishing content on the
platform. The majority of cookies used by Discourse are session cookies that expire when the user closes the
browser. On the other hand, cookies that relate to user preferences on the platform (theme used and text
size) last for 1 year.
By default, Discourse does not use analysis cookies, nor does it use cross-site cookies or ad targeting cookies.
This data will be processed exclusively within the scope of the purposes identified above.
In accordance with the principles of proportionality and necessity, the data will not be kept for longer than
is strictly necessary for the fulfilment of the above-mentioned purposes and, therefore, for the provision of
the service or for the fulfilment of specific legal requirements.
8. Legal basis, changes and updates to policy
Data is processed on the basis of the explicit consent of the data subject.
This policy is valid starting from the date indicated in its heading.
The University of Salerno may also make amendments and/or additions to this policy, also as a consequence
of any subsequent amendments and/or additions to the Privacy Regulation.