The Italian green pass can start, even the Privacy Guarantor has given a positive opinion, asking for guarantees and clarifications, first of all on the purposes of this same “green certificate”. We remind you that the green pass is a certificate that, according to modalities that will be active by July 1st, will be available to users who have been vaccinated, recovered or have had a negative covid-19 swab. The current rules provide that users with green passes will be able to access public events, sports, civil and religious parties and ceremonies. To obtain it, the Government has already provided various tools, including apps. The Guarantor has confirmed the validity of all these tools today, except the IO app because in this case the user data can transit on non-European infrastructures.
anticipation
The technology behind the Green Pass
by Alessandro Longo
The uses of the green pass. As for the use of the pass, the Guarantor asks for a primary rule that precisely establishes the cases in which the interested party may be asked to exhibit the green certification to access places or clubs, such as parties for civil and religious ceremonies, discos. This specification according to the Guarantor should be in the conversion into law of the Reopening decree, which has already provided for the possibility of using the green pass to allow travel between orange or red Regions and access to public and sporting events, participation in events, parties. The Guarantor complains precisely the current indeterminacy of the circumstances in which the display of the green pass is required has favored the adoption, by some Regions and Autonomous Provinces, of ordinances that have imposed its use also for purposes other than those provided for in the reopening decree and in respect of which the Guarantor has already intervened.
The Authority also underlines that the European regulation on the green pass, currently being adopted, also provides that the same can be used by the Member States for other purposes, with respect to travel within the EU, but only if this it is expressly provided for and regulated by a national standard.
Nobody will be left behind: this is how minors and those without internet will get the Green Pass
by Alessandro Longo
Another critical aspect is how to verify this green pass. The Guarantor fears that citizens’ data are managed in an arbitrary and potentially dangerous way. So today indicates that the standard must provide that certifications can be issued and issued only through the national platform-DGC and verified exclusively through the VerificationC19 App. “This app is in fact the only tool capable of guaranteeing the validity of the green certification up-to-date, in compliance with the principles of protection of personal data, also ensuring that verifiers can only know the personal details of the data subject, without viewing the other information present in the certification (healing, vaccination, negative result of the swab) “, explains the Guarantor.
Another measure, requested and obtained by the Guarantor during the discussions with the Ministry of Health, is that the subjects in charge of green certification checks are clearly identified and instructed.
The tools to get the pass
As mentioned, the current decree makes it possible to obtain the green pass through various digital tools (website of the National Platform-DGC; Electronic health record; Immune App; App IO) as well as with a print from the pharmacist or family doctor. In this regard, the Guarantor has authorized these methods, but has postponed the use of the App IO due to the criticalities found in relation to the same. In the same meeting of the Board, with a separate provision, the Authority, in relation to general critical issues on the functioning of the App IO, urgently ordered the company PagoPA to temporarily block some data processing carried out through the aforementioned app. which involve interaction with Google and Mixpanel services, and which therefore involve a transfer to third countries (eg USA, India, Australia) of particularly delicate data (eg cashback transactions, payment instruments, holiday bonuses), carried out without the users having been adequately informed and have given their consent.
Profiles on which the Authority had already drawn attention with various provisions of 2020, also providing indications to make the use of the app compliant with the privacy legislation. The only app “saved” by the Guarantor is therefore Immuni for now. Surprising result when you consider the privacy concerns associated with the fact that this app manages covid-19 tracking and its use is strictly anonymous. But this will remain, even with the green pass, a reason that convinced the Guarantor to give the green disc.
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