Data Protection & Cyber Security

Cugia Cuomo & Associati provides regulatory assistance in the area of privacy and data security. The firm, in particular, regularly advises electronic communications operators, including internet content providers, broadcasting companies, private entities that process personal data within the framework of information systems used for the purposes of consumer credit and/or concern reliability and timeliness of payments and/or commercial information, referring to the implementation of the security measures for the protection of personal data, conducting activities' of:


  • Compliance with General Data Protection Regulation and Italian data protection Code;
  • Draft of Data Protection Impact Assessment (DPIA);
  • Assistance on information and data subject rights;
  • Assistance on General Obligations of Controller and Processor;
  • Assistance on implementation of appropriate technical and organisational measures to ensure a level of security appropriate to the risk;
  • Advice on notification of data breach to the authorities and consumers, implementation of data retention policies in the IT industry, policies, including procedures for access to personal data of users,
  • Appointments of Data Processor, person in charge of processing , System Administrator figures, and Data Processor Officers;
  • Advice on records of processing activities;
  • Analysis of the network architecture and the security measures;
  • Advice on transfers of personal data to third countries or international organisations;
  • Advice on Binding corporate rules;
  • Compliance with call center regulation;
  • Drafting and / or review of company privacy policies,
  • Drafting and / or review of privacy and cookies policies on the website;
  • Drafting of models of agreement to the privacy policies, also in relation to commercial and advertising activities
  • Drafting or review of standard of written statement related to the consent of the data subject's agreement to the processing of personal data relating to him or her;
  • Assistance related to Obligations Applying to Providers of Publicly Available Electronic Communications Services
  • Compliance of IT databases for the filing of traffic and personal data;
  • Definition of minimum standards of data processing (strong authentication, logging, remote administration, etc.)
  •  Compliance with rules applicable to the data retention;
  • Assistance in case of litigation both in front of the ordinary Courts and of the Special Authorities

The Firm has also a deep knowledge of IT sector specific privacy regulations, particularly as mobile communications are concerned, as, for instance, regarding matters of:

  • IoT and M2M;
  • users geo-localization
  • users profiling for marketing purposes;
  • legal profiles relating to chronologic and typing-related web searches
  • definition of actors responsibilities in relation to IT products (telecoms operator, application developer, software developer, content provider, advertiser)

 The Firm usually assists electronic communication operators under the Data Protection Code (Legislative Decree No. 196 of 30 June 2003, “DPC”), and the Decision of the Italian Data Protection Authority, in order to comply with the following resolutions: 

  • “Security In Telephone And Internet Traffic Data” of 17 January, 2008, which requires the provider of electronic communication services to take specific measures and arrangements, such as strong authentication techniques, and encryption-based technical measures to safeguard data subjects in connection with the processing of telephone and Internet traffic data


  • “Implementing Measures with Regard to the Notification of Personal Data Breaches” of 4 April, 2013, which specifies the content of the “security and personal data breach Plan”, required by Article No. 32 bis of DPC, taking account of the Recommendations of ENISA (the European Network and Information Security Agency) and the obligation of data breaches notification to the Data Protection Authority;


  • “Measures and arrangements applying to the controllers of processing operations performed with the help of electronic tools in view of committing the task of system administrator” of 27 November, 2008, which sets out measures and arrangements to be implemented by all the controllers of processing operations concerning personal data that fall within the scope of application of the DPC and are carried out with the help of electronic tools.

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