Plaisant Srl Whistleblowing ex D.Lgs. 24/2023

Plaisant Srl has implemented an anonymous reporting system in accordance with the provisions of the implementing decree of Directive (EU) 2019/1937.

It is possible to report with a guarantee of confidentiality and anonymity by accessing the website at wb.exositalia.it.

Additionally, reports can be made directly at the Rome office of the Whistleblowing Manager of Plaisant Srl, Avv. Francesco Zanardelli, by appointment made by phone at 0685357830 or by email at segnalazionianonime@ult.it.

Reports through this internal channel can be made by employees, managers, executives, permanent collaborators and professionals, interns, and volunteers, including pre-employment, as well as any other subject defined by art. 3 of Legislative Decree 24/2023.

Information provided should be “detailed accounts of unlawful conduct (unlawful activities), relevant and based on precise and consistent facts, or violations of European standards that have come to their attention in the course of their duties.”

Plaisant Srl and the Whistleblowing Manager guarantee the rights of the whistleblower and the confidentiality of the report, as well as compliance with the Legislative Decree mentioned above.

It is also possible, within the legal terms and conditions, to make reports through an external channel by accessing the platform published on the ANAC website. Public reporting is also possible within legal terms and conditions.

Following is the Privacy Information of Plaisant Srl as the data controller for the Whistleblowing service:

1) Categories of personal data

a) Common personal data as per Article 4, point 1, of the GDPR of the Whistleblower (in the case of non-anonymous reports) and any Persons involved or mentioned in the Report and Facilitators, as defined by the Whistleblowing Procedure (hereinafter “Concerned Parties”), such as: personal data (e.g., name, surname, date and place of birth), contact details (e.g., landline and/or mobile phone number, postal address/email).

b) Special categories of data as per Article 9 of the GDPR, if included in the report.

2) Purposes of processing and related legal basis

The above-mentioned personal data are processed by the Controller for the following purposes:

a) management of the Report made pursuant to Legislative Decree no. 24/2023;
b) compliance with obligations provided by law or European regulations;
c) defense or assertion of its rights in civil, administrative, or criminal litigation.

The legal basis for processing is constituted: – for the purpose mentioned in letter a), by the fulfillment of a legal obligation to which the data controller is subject (Article 6, paragraph 1, letter c) of the GDPR); also, for reports recorded orally or in oral form, by the consent of the Whistleblower (Article 6, paragraph 1, letter a) of the GDPR); – for the purposes mentioned in letter b), by the fulfillment of a legal obligation to which the data controller is subject (Article 6, paragraph 1, letter c) of the GDPR). – for the purposes mentioned in letter c), by the legitimate interest of the data controller (Article 6, paragraph 1, letter f) of the GDPR). The provision of data is necessary to achieve the above-mentioned purposes; failure, partial, or inaccurate provision could result in the impossibility of managing the report.

3) Storage of personal data

Plaisant retains personal data as provided by Article 14 of Legislative Decree no. 24/2023, i.e., for the time necessary for the processing of the report and in any case for no more than 5 years from the date of communication of the final outcome of the Report. Personal data that is manifestly not useful for the processing of a specific report is not collected or, if collected accidentally, is promptly deleted.

4) Methods and logic of processing

Data processing is carried out manually and/or through automated computer and electronic tools with logic related to the above-mentioned purposes and, in any case, in such a way as to ensure their security and confidentiality. The Whistleblowing Management System ensures, at every stage, the confidentiality of the identity of the Whistleblower, the Persons involved and/or mentioned in the Report, the content of the Report, and related documentation, except as provided by Article 12 of Legislative Decree no. 24/2023.

5) Categories of third-party subjects to whom data may be communicated

Some processing may be carried out by third parties, to whom Plaisant Srl entrusts certain activities (or part of them) for the purposes mentioned in point 2); these subjects will operate as Data Processors and are essentially included in the following categories:

a) Consultants (Organization, Litigation, Legal Studies, etc.)
b) Companies entrusted with personnel administration and management,
c) Institutions and/or Public Authorities, Judicial Authorities, Police Bodies.

 6) Rights of the data subjects

segnalazionianonime@ult.it
In addition, the data subject has the right to lodge a complaint with the Guarantor for the protection of personal data. The aforementioned rights cannot be exercised by the person involved or mentioned in the report, for the time and within the limits in which this constitutes a necessary and proportionate measure, pursuant to Article 2undecies of the Privacy Code, as the exercise of such rights could result in an actual and concrete prejudice to the protection of the confidentiality of the identity of the reporting person.