Why this page?
The answer is that this page describes the rules for processing the personal data of the visitors of the website www.fondazionecnao.it, its subdomains and related pages, such as course registration pages, and summarizes the main processing operations carried out by CNAO.
The data Controller of these personal data is.
Fondazione CNAO - Via Erminio Borloni, 1 - 27100 PAVIA - firstname.lastname@example.org
The Data Protection Officer of Fondazione CNAO can always be reached at email@example.com.
Data processing related to the web services of this site is in the care of by CNAO staff, as well as by the specialized provider duly entrusted with the Press Office and by the site provider.
The website is handled and hosted by a specialized provider, duly appointed as a data processor.
For clarification, information or further details you can always write to firstname.lastname@example.org or our DPO.
In general, specific short information notes are reported or displayed on the pages set up for particular services (e.g. access to therapy, doctors' restricted area, newsletter subscription ...), which are summarized and detailed here.
Access to therapy and specialist televisits
Those wishing to access the services offered by CNAO and request an assessment of eligibility for treatment with Hadrontherapy must transmit information about their health status and other very personal information to our clinical team, which may in case also share it with other specialists for multidisciplinary consultation, so as to obtain their assessment, either directly or through the treating doctor. In this sense, the processing of personal information is performed in execution of the contract between the parties (potential patient and CNAO).
Whatever the type of potential patient and of request (resident, international, with SSN regime, solvent, second opinion applicant...), the interested party must follow a
procedure that can be activated through this website and allows the complete and secure transmission of all the information necessary to accomplish the evaluation.
The document delivery system employed on this site is encrypted: no personal information is stored on the site, but delivered directly to the recipient and not
accessible to third parties.
Those who request the assessment through their treating doctor, thanks to the dedicated tools for doctors described below, will have to give their doctor a consent
to share the data with CNAO, in order to proceed to the assessment of the case.
All requested information is used for the sole purpose of accomplishing the preliminary assessment of the clinical case, necessary to determine whether the
patient may be a candidate for Hadrontherapy treatment; failure to provide the data prevents us from proceeding with the assessment. The information is processed only by healthcare staff performing clinical triage.
Whatever the outcome with respect to eligibility for hadrontherapy treatment, the concerned person's identifying data, diagnosis, and list of the evaluated
documentation will be stored in databases by CNAO, in a secure mode, for 10 years after the response.
In cases of request and follow-up of preliminary specialist tele-visits, the concerned person will receive specific information via email and the data collected will be
processed by the clinical staff for evaluation and stored for 10 years, as required by regulations in force in matter of outpatient visits.
In case of access to hadrontherapy treatment, the concerned person will receive specific information at the first access to our Center which will indicate the storage of
his or her clinical data in the digital file with indefinite duration, as provided for by the regulations in force in matter of radiotherapy outpatient healthcare assistance.
Video surveillance in the facility
In some areas of the CNAO buildings, both inside and outside (e.g., in the parking lot), video cameras are installed for security and radiation protection purposes, in the legitimate interest of CNAO to protect people (whether they be patients, workers, or visitors) and its assets.
The cameras are located at access points to the building and floors, in the paths from and to the synchrotron room, and along the patient path. Namely, there are cameras in each treatment room that are viewed by the medical staff administering the therapy, installed for the sole purpose of ensuring patient safety.
All images are recorded, and video recordings, kept for the strict necessary time (72 hours), can only be viewed in case of incidental events or at the explicit request of judicial authorities.
To protect our personnel at work, videotaping and recording is forbidden within CNAO.
Medical Doctors’ Area
With the registration in the restricted area for medical doctors, the data provided are used, in execution of the contract between the parties, to:
- verify the legitimacy of the request for access to the restricted area
- allow access to the area dedicated to the publication of information related to or concerning the scientific research carried out by the CNAO Foundation
- allow access to web services dedicated to medical doctors such as consultation via chat or video
- transmit the scientific information newsletter prepared by the CNAO Foundation
The data collected are identification and contact information (email), including professional record membership references suitable for verifying identity and membership in the categories of medical doctors who can access the restricted area, and the provision of data is mandatory for the provision of the service.
Data are not conferred to third parties and are accessible only to the staff of the CNAO Foundation Communication Office, the specialized provider that manages this website, and the Press Office.
Data are deleted by the subscriber upon request to be addressed to email@example.com or firstname.lastname@example.org.
Submit a clinical case
Within the restricted area, a remote consultation service is available at CNAO, through which external doctors can request from our Medical Service an opinion or
indication of applicability of Hadrontherapy in certain cases.
Through the medical consultation chat system, the doctor’s identification data used for registration are processed.
In the event, though, that the requesting doctor wishes to submit to us specific information regarding one or more patients and/or request an initial assessment of
eligibility for treatment, it is necessary for the requestor to obtain consent from the patient to discuss his or her case (and thus `to transmit his or her data, also but not
exclusively regarding the health status) to CNAO Foundation for clinical evaluation.
Therefore, in this case, data from potential patients are also processed for the purpose of clinical evaluation and based on the execution of the contract between
CNAO and potential patient, who is informed in advance by his or her doctor. The information thus collected is used with the sole purpose of performing the preliminary clinical case evaluation as described in the appropriate section of this information notice.
Teleconsultation in Radiation Oncology Therapy
The video-consultation system is connected to the Microsoft Teams platform, and managed by the provider in charge of this website, on servers within the European Union.
Video calls take place live, by reservation, and are not recorded.
They take place on an encrypted channel, with access allowed only to medical doctors who have registration to the medical doctors’ area, through a Guest user.
CNAO processes, for the sole duration of the video call:
- data belonging to the requesting doctors (identifiers, video and audio)
- any information the doctor intends to share about the patients.
In order to discuss a person's specific case, we ask each doctor to ask the patient for consent to share data with the CNAO Foundation for the clinical evaluation. Any documents related to the case are shared through the chat system, to do it in a secure and tracked manner.
Thus, the processing of personal data is carried out, both with respect to the medical doctor (to provide the consultation service) and with respect to the potential patient (to evaluate the clinical case) in execution of the contract between the parties.
Video consultation information is not accessible to anyone.
In order to manage guided tours at our centre, physical or virtual, we need to receive and manage seat reservations and possibly to communicate with the applicant. The personal information requested for registering for a guided tour (identification and contact information) is therefore necessary, in execution of the contract, to be able to manage registrations and contact those who book in case of changes or cancellations of the event. The contact information of one contact person per booking is sufficient.
The data are collected and handled by the Guided Tours Office of the CNAO Foundation, they are not disclosed to third parties, and are deleted at the end of each tour cycle.
In addition, if the data subject provides consent in the completion form, we will use the entered email address to send informative communications and news about the CNAO Foundation activities, including invitations to participate in events or surveys and fundraising campaigns.
For this purpose, the CNAO Communications Office and the specialized suppliers in charge of communication activities will use exclusively the concerned subject's address data. The data will be kept and used until the termination of the service, which can be requested at any time from the footer of the same, preventing their subsequent transmissions.
Courses, events, conferences (including distance learning)
In order to organize training, conference, and information dissemination events on Hadrontherapy, we need to receive and manage registrations and in case communicate with the applicant. The personal information requested for registration in the individual event (generally identifying and contact information) is therefore necessary, in execution of the contract, in order to be able to deal with registrations and contact registrants for information or changes or cancellations of the event. For the management of some events CNAO uses the booking service offered by Eventbrite, appropriately appointed as Data Processor.
Data are collected and managed by the Communication and Training Offices of the CNAO Foundation, and may be conferred to the web page managers and the event organizational secretariats, and are stored according to the rules specified for the individual event.
Recipients' mailing addresses could be used, as per the following paragraph, also to send the clinical newsletter in the legitimate interest of CNAO.
CNAO periodically broadcasts a scientific information newsletter intended for all medical doctors who may be interested in receiving information about hadrontherapy treatment. The newsletter is transmitted to all persons who spontaneously subscribe to the restricted area and/or to our specialist courses on Hadrontherapy, as well as to specialists with public email addresses given on the websites of targeted scientific societies, referral hospitals or relevant regional ATSs, based on the legitimate interest of the CNAO Foundation to spread knowledge related to Hadrontherapy.
For this purpose, the CNAO Communication Office and the specialized providers in charge of communication activities will use exclusively the data of the data subject's contact information. The data will be kept and used until the data subject exercises the opt-out to receive the clinical newsletter, which can be done at any time from the footer of the newsletter, preventing their subsequent transmissions.
Notification and Report form
CNAO makes available a notification and report form that can be accessed from the patient area, through which individuals can inform the Communication Office of any misconduct that occurred during their time spent at our facility. The report can be filled out by all persons who have used CNAO's services and handed in at the reception desk or sent to the address email@example.com.
Information is processed on the basis of CNAO legitimate interest in ensuring the best possible experience for its patients and visitors.
The data of the reporter and the content of the message will be accessible only to authorized personnel and will be retained for as long as necessary for the processing of the report and deleted within 1 year from the date of delivery of the report in order to allow for all appropriate verifications.
Newsletter for the general public
All users of this site or of CNAO services who are interested in staying informed about our activities can request from the footer of the site (or from any other forms contained in appropriate landing pages or documents) their subscription to the newsletter, in order to thus receive, via email, informative communications and news about the CNAO Foundation activities, including invitations to participate in events or surveys and fund raising campaigns.
For this purpose, the CNAO Communication Office and specialized suppliers in charge of communication activities will use exclusively the data subject's address data. The data will be kept and used until the termination of the service, which can be requested at any time from the footer of the same, preventing their subsequent transmissions.
Work with us
In the dedicated section of this website, interested individuals can submit their applications or reply to one of our job searches. In doing so, they are asked to forward their CV to the CNAO Foundation.
The data contained in the CV and collected in the selection process will be used by the dedicated staff of the Human Resources and Legal Affairs Office of the CNAO Foundation for the sole purpose of evaluating the application and concluding a possible collaboration contract.
Forwarding the CV is mandatory for participation in the selection process. The data thus collected are stored in electronic format by the CNAO Human Resources and Legal Affairs Office for a period of 5 years and are not accessible to third parties.
The data subjects may always request that the data be updated during the storage period. They may also request their deletion, which may be granted in all cases where the application has not been inserted on a ranking list, in which case they will be stored until the end of the aforementioned period. To do so, the data subjects may contact the Human Resources Office or write to firstname.lastname@example.org (we will redirect the request).
Questions or contact requests
The optional, explicit and voluntary sending of electronic mail messages to the addresses indicated on this site entails the subsequent acquisition of the sender's address, which is necessary to reply to requests, as well as of any other personal data inserted in the message (the processing of these data is carried out in execution of the contract between the parties). The data thus transmitted will be stored for the entire duration of the relationship between the parties and in general for the legal retention time of administrative documents.
Cookies are small text strings that a website can send, during navigation, to your device (be it a pc, notebook, smartphone, tablet). They are usually stored directly in the browser used for browsing. The same website that transmitted them can then read and record cookies that are on the same device to obtain various types of information.
The CNAO Foundation uses technical cookies, designed to improve the experience on its site (and thus in execution of the service). Data from technical cookies are in case accessible only to the specialized provider that manages this website and are deleted at the end of each session.
The CNAO Foundation uses third-party statistical cookies, namely Google Analytics, which are used to monitor in aggregate form the performance of the site, for example to know the number of pages visited or the number of users who have viewed a particular section. In general, the analysis of these cookies generates aggregate statistical data without any reference to the identity of the site's surfers. This information is also useful for evaluating possible changes and improvements to be made to the site itself. This cookie is not a tool we own, for more information, therefore, you can consult the information notice provided by Google at the following address: http://www.google.it/policies/privacy/partners/. The CNAO Foundation only receives aggregate information from Google, but Google can track individual user behaviour by using the information for its own purposes.
The CNAO Foundation uses profiling cookies tout-court for the purpose of spreading information about Hadrontherapy and related treatment options to specialist users. Profiling cookies, based on Google Tag Manager, track user behaviour on certain pages of the site (e.g., the one on the clinical therapeutic pathway) to provide targeted communications through social media as well. The profiling activities and consequent exposure to targeted communications are typically addressed to a target audience of specialized professionals with whom the CNAO Foundation intends to interface in order to spread the culture about Hadrontherapy, the pathologies treatable by CNAO, research, available FAD and CME courses, and everything related to the dissemination of the topic "Hadrontherapy." Actions addressed to non-specialist users typically concern awareness of the center and its activities and/or promote fundraising or donations.
For this reason, when you access the site and at certain intervals we will ask you if you give us consent to activate analytical and/or profiling cookies or if we should leave them inactive. If you give consent but then change your mind, or otherwise prefer not to be tracked, you can always:
- view the detail of cookies issued by this site, accessible from the consent request banner, (which can be viewed by simply clearing your browser cache), clicking on the "I configure cookies" icon and requesting the detail from the "show details" button. The options can be changed at any time.
- Use anonymous browsing (Do Not Track option) of your browser. To find out how to enable the option on the major search engines click on the browser you use: Internet Explorer, Google Chrome, Mozilla Firefox, Apple Safari.
- Choose to disable Google Analytics by installing the disable add-on on your browser. Click here to download it.
What are the users' rights and how can they be exercised?
The individuals, to whom the personal data refer, in their quality of concerned subjects, have the right at any time to obtain from CNAO Foundation confirmation of the existence or non-existence of the same data and to know their content and origin, as well as to request their rectification, cancellation or processing limitation. They also have the right to file a complaint with the Data Protection Guarantor Authority for alleged violations of current regulations.
All rights summarized above can be exercised by writing to: email@example.com or by following the information detailed in the individual notices. It will in any case be our care to respond to you without delay.