Introduction and Policy Statement
If there is any conflict between the policies in this statement and the Principles, the Principles will govern. This statement outlines the general policy and practices for implementing the Principles, including the types of information Cantina Mingazzini S.r.l. gathers, how the information is used, and the choices affected individuals have regarding Cantina Mingazzini S.r.l.’s use of, and their ability to correct, that information.
The use of EU employee Personal Data will include global enterprise headcount reporting, statistical analysis, compensation planning and related transactions, career development, staffing, international personal security issues, internal investigations, ethics investigations, law enforcement inquiries, U.S. Government agency inquiries, and mergers, acquisitions, and divestitures.
The EU adopted the Directive on Data Protection (“EU Directive”), which requires EU member states to adopt laws protecting Personal Data collected within their borders. These laws must, among other provisions, restrict the transfer of Personal Data only to countries that have data protection laws deemed “adequate” under standards established in the EU Directive. The U.S. Department of Commerce and the European Commission have agreed on the Principles to enable U.S. Companies to satisfy the requirement under EU law that adequate protection be given to Personal Data transferred from the EU to the U.S.
Identifiable Person – means a natural person that is or can be identified, directly or indirectly, as a particular person by reference to an identification number or to one or more aspects of the person’s physical, physiological, mental, economic, cultural or social identity. Identifiable Persons may include any employee, applicant, former employee, or retiree of Cantina Mingazzini S.r.l., its operating divisions, or subsidiaries in the EU.
Personal Data – is any information about an Identifiable Person that is within the scope of the EU Directive, is received by Cantina Mingazzini S.r.l. in the U.S. from the EU, is recorded in any form and is about, or pertains to, a specific individual; and can be linked to that individual.
Personal Data does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Data.
Processing – means any online, offline or manual processing and includes such activities as copying, filing, and inputting Personal Data into a database.
Sensitive Data – is data that pertains to medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual orientation or any other data that is identified as “sensitive” by the Identifiable Person.
Where Cantina Mingazzini S.r.l. collects Personal Data directly from Identifiable Persons in the EU, it will inform them about the type of Personal Data collected, the purposes for which it collects and uses the Personal Data, and the types of non-agent third parties to which Cantina Mingazzini S.r.l. discloses or may disclose that information, and the choices and means, if any, Cantina Mingazzini S.r.l. offers individuals for limiting the use and disclosure of their Personal Data. Notice will be provided in a clear and conspicuous language when individuals are first asked to provide Personal Data to Cantina Mingazzini S.r.l., or as soon as practicable thereafter, and in any event before Cantina Mingazzini S.r.l. uses or discloses the information for a purpose other than that for which it was originally collected.
Where Cantina Mingazzini S.r.l. receives Personal Data from their subsidiaries or operating divisions in the EU, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to which the Personal Data relates.
To the extent practical and appropriate, Cantina Mingazzini S.r.l. collects Personal Data directly from the Identifiable Person. In those cases where Cantina Mingazzini S.r.l. collects Personal Data from other persons, it takes measures to respect the privacy preferences of the Identifiable Persons. Examples of when Cantina Mingazzini S.r.l. may seek information from others include, without limitation, evaluating employees, recruiting, benefit administration and succession planning.
Cantina Mingazzini S.r.l.’s collection and use of Personal Data in the employment context is essential to the conduct of Cantina Mingazzini S.r.l.’s human resources and business functions. Examples of the purposes for which Cantina Mingazzini S.r.l. collects and uses Personal Data include, without limitation, recruitment, payroll, and personnel management, such as compensation, promotion, evaluation, benefit administration and succession planning.
While recognizing that all Personal Data deserves to be protected, Cantina Mingazzini S.r.l. exercises special precautions and safeguards for Sensitive Data. Unless required by applicable law, Cantina Mingazzini S.r.l. does not request or record Sensitive Data.
Cantina Mingazzini S.r.l. will offer Identifiable Person(s) the opportunity to choose (opt-out) whether their Personal Data is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
In addition, where consent of Identifiable Persons or their representatives is required by law, contract, or agreement for the collection, use, or disclosure of Personal Data, Cantina Mingazzini S.r.l. will request such consent and respect the Identifiable Person’s choice in such matters.
In certain limited or exceptional circumstances, in accordance with the Safe Harbor Principles, Cantina Mingazzini S.r.l. may disclose Personal Data without notice or the consent of the Identifiable Person. For example, this may occur when Cantina Mingazzini S.r.l. is required to disclose information by law or legal process or in the vital interests of the Identifiable Person, such as when life or health are at stake.
Except as provided by the Safe Harbor Principles or applicable law, an Identifiable Person must give affirmative permission (opt in consent) before Cantina Mingazzini S.r.l. will disclose Sensitive Data to a third party or use Sensitive Data for a purpose other than those for which it was originally collected or subsequently authorized by the Identifiable Person.
Cantina Mingazzini S.r.l. will provide Identifiable Persons with reasonable mechanisms to exercise their choices.
To enable Cantina Mingazzini S.r.l. to provide employees with certain services such as payroll direct deposit, personnel benefits, or other human resource services, Cantina Mingazzini S.r.l. may disclose Personal Data without consent to sub-contractors, vendors or other third parties, if the third party (i) subscribes to the Safe Harbor Principles, (ii) is subject to laws meeting the minimum standards required by the EU Directive or (iii) enters into an agreement with Cantina Mingazzini S.r.l. obligating the third party to provide at least the same level of privacy protection as required by Safe Harbor Principles.
Cantina Mingazzini S.r.l. takes reasonable precautions to protect Personal Data against loss, misuse and unauthorized access, disclosure, alteration, destruction and theft.
These precautions include password protections for online information systems and restricted access to Personal Data. All inquiries from outside Cantina Mingazzini S.r.l., whether written or oral, concerning the identity, employment record or performance of an employee or former employee must be referred to the Human Resources Department.
Employees are responsible for helping maintain security through safeguarding Personal Data, e.g., by protecting passwords used to access Cantina Mingazzini S.r.l. computer systems, by keeping paper records under lock and key when not in use, and by disposing of files and reports no longer needed in a secure manner.
Cantina Mingazzini S.r.l. takes reasonable steps to keep Personal Data accurate, complete, and up-to-date. Each Identifiable Person is responsible for informing Cantina Mingazzini S.r.l. or its EU subsidiaries of any changes in Personal Data so that the information that Cantina Mingazzini S.r.l. holds about him or her is accurate, complete and up-to-date.
Cantina Mingazzini S.r.l. retains Personal Data only as long as necessary to meet the purposes for which it was collected or as required by law, contractual agreement, or the Safe Harbor Principles.
Certain Personal Data may be archived to administer post-employment benefits, to meet legal requirements, to provide evidence in cases of litigation, for statistical purposes, or to assist in decision relating to re-employment.
Cantina Mingazzini S.r.l. uses reasonable procedures, following retention guidelines, to ensure that it archives or destroys Personal Data no longer required for the purposes for which it was originally collected, unless otherwise agreed to by the Identifiable Person.
Cantina Mingazzini S.r.l. provides Identifiable Persons with a reasonable opportunity to examine their Personal Data, to challenge its accuracy and to have it corrected, amended or deleted as appropriate, subject to certain exceptions. Upon request, Identifiable Persons will be given reasonable access to the Personal Data Cantina Mingazzini S.r.l. holds about them. Reasonable access means that requests for access are made during normal business hours, following standard procedures, and that the frequency of access requests is not excessive.
If an Identifiable Person is denied access to Personal Data, Cantina Mingazzini S.r.l. will provide such Identifiable Person with the reason(s) for denying access and a contact point for further inquiries.
If the Identifiable Person notifies Cantina Mingazzini S.r.l. that the Personal Data on file is incorrect and provides Cantina Mingazzini S.r.l. with appropriate supporting documentation, Cantina Mingazzini S.r.l. will either correct the Personal Data or direct the Identifiable Person to the source of the information for correction.
If, upon review, Cantina Mingazzini S.r.l. believes that the existing Personal Data is correct, Cantina Mingazzini S.r.l. will inform the Identifiable Person. If the Identifiable Person continues to dispute the accuracy of the Personal Data, Cantina Mingazzini S.r.l. will note that dispute in the record of the Identifiable Person upon written request.
The Safe Harbor Principles provides for some exceptions to the obligation to provide access to Personal Data. Access to confidential or proprietary information, such as business reorganization or succession plans, or where granting access has to be balanced against the privacy interests of others, may be restricted. In addition, access may be denied when the information requested relates to an ongoing investigation, litigation or potential litigation, where the burden or expense of providing access would be disproportionate to the risks to the privacy of the Identifiable Person or when the rights of persons other than the Identifiable Person would be violated.
Enforcement and Dispute Resolution
For complaints that cannot be resolved between Cantina Mingazzini S.r.l. and the complainant, Cantina Mingazzini S.r.l. has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Principles.
Cantina Mingazzini S.r.l.’s privacy practices are self-certified annually to the U.S. Department of Commerce.
Cantina Mingazzini S.r.l.’s ownership is responsible for:
Overseeing responses to inquiries and resolutions of complaints relating to the privacy of Identifiable Persons;
This policy may be amended by time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on Cantina Mingazzini S.r.l.’s web page at www.vinaporter.cantina-mingazzini.com
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