Disclaimer - Food Wave


Information Notice on Data Processing

pursuant to art. 13 of the EU Regulation 2016/679

In accordance with Art. 13 of EU Regulation No 2016/679 (General Regulation on the protection of personal data), the following information is provided.



The European project “Food Wave – Empowering Urban Youth for Climate Action” aims to raise public awareness of development issues and promote development education in the European Union.” It is based on awareness-raising and engagement campaigns on the key issue of climate change and urban food policies. The focus is also thought to be related to social inclusion.

The project is developed by the Municipality of Milan, together with civil society organizations and other Italian, European and global partners (29 in total) who perform their functions in full autonomy and hold the status of autonomous Data Controllers. These subjects will separately make the privacy notice on the processing of the data they hold.


Data Controller

The following information therefore refers only to the treatments carried out by the Municipality of Milan in its capacity as owner based in Piazza della Scala, 2 – 20121 Milan as part of the promotion and implementation activities of the Food Wave project.

The project plans to document the interventions and activities of the subjects involved in the project initiatives through images, video footage and audio recordings.


Data Protection Officer’s Contact Details – DPO

The Data Protection Officer (DPO) of the Municipality of Milan can be reached at the following e-mail address: dpo@comune.milano.it  


Purpose and legal basis

The processing of data is carried out through images, video footage and audio recordings of the activities planned as part of the project, aimed at raising the awareness of young people aged 15 to 35 about the food-climate nexus and the dissemination of the culture of sustainable urban food production and consumption practices for climate change mitigation.


Personal data are processed in compliance with the conditions laid down in EU Regulation 2016/679 and in particular:

a) in the light of art.6, paragraph 1 (.b) for the performance of the contract to which the data subjects are parties by registering with the platform;

b) in the light of art. 6, paragraph 1 (.c) and art. 2 ter of Legislative Decree 196/2003 “Code on the protection of personal data”, for the execution of a task of public interest in accordance with the project objectives;

c) in the light of 6, paragraph 1 (.a) on the basis of consent in relation to the possible transfer of data to non-EU countries or outside the EEA (European Economic Area)

The consent given regarding the subject referred to in point (c) above may be revoked at any time by contacting the Data Controller at the e-mail address DS.Polcomunitarie@comune.milano.it


Methods of data processing

The processing takes place in compliance with fundamental rights and freedoms and is based on the principles of fairness, lawfulness, transparency and protection of confidentiality ensuring the relevance and proportionality of the information collected and used in relation to the purpose described. The processing is also carried out with the help of electronic tools and includes in particular to share and publish the audio and video images and recordings made as part of the Food Wave project.


Nature of data processing

Participation in the initiatives organized within the framework of the Food Wave project, the sharing and publication of audio and video images and recordings, is free and voluntary and will be carried out, subject to release of the Disclaimer, through the www.foodwave.eu platform or through different communication tools and channels such as food wave social channels, as well as the websites and social channels of the project partners adopting the appropriate technical and organizational measures.


Communication and Dissemination

Personal data may be shared with food wave project partners (listed below) who will act as independent data controllers, required to make their information on the processing of Core Team data: ActionAid Italia, ACRA, Mani Tese Cities and municipal agencies: City of Almere, Metropolitan Agency of Brazov, City of Bruges, ReLondon, City of Malmö, City of Madrid, Municipality of Molenbeek, City of Murcia, Municipality of Nea Smyrni, Pest County, City of Turin, City of Sao Paulo, City of Sofia, City of Warsaw, City of Zagreb, Risteco – Eating City Civil society organizations: Institute Wcycle Maribor, European Association for Local Democracy – ALDA, ActionAid Hellas,Fundación Alianza por los Derechos, la Igualdad y la Solidaridad Internacional, Biennale des jeunes créateurs de l’Europe et de la Méditerranée – BJCEM, Erasmus Student Network Italy – ESN Italy, Lisbon CLLD Network, Groundwork Greater Manchester. The communication and dissemination of data must take place exclusively for the purposes indicated related to the Food Wave project. 


Recipients or Categories of data recipients

The processing is carried out by the authorized persons and committed to confidentiality and in charge of the related activities in relation to the purposes pursued.

The processing of data will also be carried out by staff of ActionAid Italia and Pomilio Blumm, who act respectively as Data Processor and Sub-Processor ex art. 28 of the EU Regulation 2016/679 for the management of the platform and information and communication activities (sending newsletters, invitation to events, sending specific information notices related to project issues).


Data transfer to third countries

The data processed for these purposes are not, in principle, transferred to non-EU countries or outside the EEA (European Economic Area). However, in the context of the project, the possibility of transferring data to non-EU countries or international organisations is not excluded and in this case the processing can only be lawfully carried out by explicit and specific consent as indicated in point (c) of the previous paragraph “Purpose and legal basis”. With this in mind, the information may be transferred to partners in the United Kingdom (UK) or São Paulo of Brazil or to other persons for whom there is no adequacy statement from the EU Commission. Data protection measures limit the risk of processing that does not comply with the regulatory framework.


Data retention or criteria to define the period

Personal data, i.e. images, video footage and audio recordings, will be stored for as long as necessary to achieve the purposes and for the period of execution of the project and will in any case be stored in the public interest, in relation to the activities carried out as part of the Food Wave project.


Rights of data subjects

Interested parties may exercise the rights provided for in Art. 15 and the following of EU Regulation 2016/679 and in particular the right to access their own personal data, to request its rectification or limitation, to update if incomplete or incorrect and to delete if the conditions are fulfilled, as well as to oppose processing by making the request:


Finally, we inform you that the data subjects, if they believe that the processing of personal data referred to them takes place in violation of the provisions of EU Regulation 2016/679 (art. 77) have the right to lodge a complaint with the Guarantor, (www.garanteprivacy.it) or to refer the matter to the appropriate judicial bodies (Art. 79 of the Regulation)