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by Tiziana Di Giovannandrea 01 June 2020 The Guarantor for the protection of personal data has authorized the Ministry of Health to start the treatment relating to the Covid-19 Alert System (Immune App).

On the basis of the impact assessment transmitted by the ministry, the processing of personal data carried out within the System can be considered proportionate, as measures have been envisaged to sufficiently guarantee respect for the rights and freedoms of the data subjects, which mitigate the risks that could derive from treatment. 

However, taking into account the complexity of the alert system and the number of potentially involved parties, the Guarantor has in any case decided to give a series ofmeasures to strengthen the data security of the people who will download the app . These measures may be adopted as part of the testing of the system, so as to ensure that any remaining critical issues are resolved during the implementation phase. In particular, the Authority asked that users be adequately informed about the functioning of the calculation algorithm used to assess the risk of exposure to contagion. Furthermore, they must be made aware that the system could generate exposure notifications that do not always reflect an actual risk condition.

Users will also need to be able to temporarily disable the app . The data collected through the alert system cannot be processed for purposes not provided for by the law that establishes the app. The transparency of the treatment for statistical-epidemiological purposes of the collected data must also be guaranteed and suitable methods must be identified to protect it, avoiding any form of re-association with identifiable subjects and adopting suitable security measures and anonymization techniques. Measures to ensure the tracing of the operations performed by system administrators on operating systems, on the network and on databases must be introduced.

The retention of cell phone IP addresses must be commensurate with the time strictly necessary for the detection of anomalies and attacks. Measures should be taken to mitigate the risks of false positives. Attention should be paid to the information and the warning message. Finally, the Guarantor stressed that the processing of personal data collected through the app, by unauthorized subjects, may lead to an illegal processing of personal data, possibly also from a criminal point of view. 

Sileri: "Immune? I hope many will download it" 
"Privacy is respected and public health is protected, so I think many will download it and I hope as many as possible, it is part of a positive tracking system which however plays an essential role of the doctor competent in the procedure of tracing positive subjects or close contacts ". Deputy Minister of Health Pierpaolo Sileri said in an interview with Sky TG24. "It starts with a test that will last a few days - he continued - and then from next week or the next week it will be extended to all". As for the controversies on reopenings , Sileri stressed: "We were not influenced by the weight of Lombardy, absolutely not, we were instead rigorous in the calculation and evaluation of the criteria established within the Ministry of Health to evaluate reopenings safely with prudence "The data in which we are in possession show the possibility of reopening. It does not mean that we will not continue to monitor, on the contrary, where there was an increase in infections or situations that risk becoming out of control, steps will be taken".