In implementation of the EU Directive 2017/1937, Legislative Decree n.24 of March 10 2023 on “the protection of people who report violations of EU law and laying down provisions concerning the protection of people who report violations on national regulatory provisions” was issued. The Decree repeals the previous national regulations and brings together in a single regulatory regime for individuals who report violations of EU and national provisions, harmful to the public interest or integrity of the entity.
Who can report:
People who come into contact with Smi and Smigroup in a work context may submit reports. Entitled parties under the Decree are:
What can be reported:
Reportable unlawful conduct found in the Smigroup working context concern violations of the 231 Model and relevant violations pursuant to Legislative Decree 231/01.
Reportable unlawful conduct found in the working environment of Smi may concern:
Reports which affect the personal interests of the reporter are excluded.
The report must be properly substantiated and complete with useful elements for the necessary in-depth investigations.
How to report:
Reports can be done:
The European Regulation 679/2016 (GDPR) on the protection of personal data has been fully applicable since May 25th, 2018. This is an important goal, because it lays down rules relating to the processing of personal data for all Countries within the Union. Every company of the SMI Group planned a series of activities, assets or operational modes to comply with the regulation and put into practice the protection of personal data. Here is a list of actions taken to comply with the European Regulation and our policy on personal data processing.
Lawfulness of processing
All activities relating to personal data processing shall be lawful (consent, contract obligations, vital interests of the data subject or of third parties, compliance with legal obligations to which the controller is subject, public interest or exercise of official authority, legitimate interest pursued by the controller or by third parties).
Information document
The information statement has been improved and updated to the new regulations (art. 13 and 14 GDPR).
Rights of the data subjects (right of access, right to erasure-right to be forgotten, right to restriction of processing, right to object, right to data portability)
Technical and organization measures have been adopted to ensure the data subject's exercise of his rights and to meet the data subject requirements.
Controllers, processors
Based on the new principle of “accountability”, SMI Group organization was re-defined, in order to proactively ensure integral compliance with the Regulation.
Redefinition of the role of data processors and service suppliers whose activity implies personal data processing.
Risk of data processing; accountability measures taken by controllers and processors (Impact assessment, record of processing activities, security of processing, data breach)
The “Conformity document”, including records of data processing activity, plans, adopts and demonstrates all technical and organizational measures taken to adequately perform the data processing activities and specifies the necessary procedures to be adopted to notify data breach.
Transfer of personal data to international organizations
Smi Group adheres to the general principles and guarantees concerning the transfer of personal data to third Countries.
The Controller is:
SMI S.p.A.
Head office: Via Carlo Ceresa, 10 - 24015 San Giovanni Bianco (BG) - ITALIA
P.I.: 04471940165 - C.F.: 03942700166 - R.E.A.: 421708
For further information, write to: privacy@smigroup.net
According to the European Regulation 679/2016, the data subject is entitled to exercise the rights set forth in the Regulation.
The integral version of art. 15; 16; 17; 18; 20; 21; 77 of the European Regulation is attached to this document.
In order to exercise your rights, please send the application form duly filled in to the Controller's address.
SMI S.p.A.
IVA SMI INDUSTRIES Group
Headquarters: Via Carlo Ceresa, 10 - 24015 San Giovanni Bianco (BG) - ITALIA
Registered office: Via Monte Grappa, 7 - 24121 Bergamo (BG) - ITALIA
VAT: 04471940165 - TAX code: 03942700166 - R.E.A.: 421708
Share capital: Euro 5.000.000 i.v.