PRIVACY PROTECTION MODULE

City Pescara News is an American-based digital newspaper operating from the United States but owned and managed by a company fully subject to European Union legislation. Although the publication is hosted and editorially structured within the U.S.—a jurisdiction that does not recognize or implement the European “Right to Be Forgotten”—our organization voluntarily adopts and implements the highest standards of data protection defined under EU law, including Regulation (EU) 2016/679 (GDPR) and all applicable Italian and European privacy frameworks.

This Confidentiality & Privacy Protection Module outlines how we handle personal information, how we safeguard confidential communications, and how individuals may exercise the rights provided under European legislation, even when interacting with an American news platform. Our dual-system structure—European compliance combined with U.S. publishing operations—requires absolute clarity, transparency, and integrity in the treatment of all personal data. For this reason, City Pescara News adopts a hybrid model in which the strictest applicable rules always prevail.

2. Our Commitment to Confidentiality

City Pescara News is committed to maintaining the confidentiality of all materials submitted to us, whether through email, private message, upload form, telephone communication, or any other channel of interaction. Confidentiality applies to individuals, companies, institutions, journalists, partners, sources, contributors, and any subject interfacing with our editorial structure.

We guarantee that:

Confidential submissions will never be disclosed to third parties without explicit written authorization.
Personal data will never be sold, transferred, or exchanged for commercial benefit.
Sensitive materials (audio, video, documents, reports, investigative files) will be protected with advanced encryption protocols.
Our staff receives continuous training on data handling, confidentiality rules, and risk prevention.
Any breach, suspected breach, or attempted unauthorized access is immediately reported to our Data Protection Supervisor.

Even though U.S. law does not require many of these measures, we implement them voluntarily because our corporate governance is EU-based. Confidentiality, for us, is not simply a legal obligation—it is a structural principle of responsible journalism and ethical editorial practice.

3. Legal Framework: EU Law vs. U.S. Law

Because City Pescara News operates within the American media environment while being fully subject to EU law, it is necessary to explicitly define the legal landscape.

3.1. EU Laws That Apply to Us

We voluntarily align with:

Regulation (EU) 2016/679 – GDPR
EU Charter of Fundamental Rights, Article 8 (Protection of Personal Data)
Italian Privacy Code (Legislative Decree 196/2003, as amended)
European guidelines on journalism, confidentiality, and data minimization

These laws require:

Purpose limitation
Data minimization
Accountability
Transparency
Strict confidentiality protocols
Respect for data subjects’ rights (access, rectification, restriction, objection, etc.)

3.2. U.S. Laws Relevant to Our Operations

The United States, unlike the EU, does not recognize:

The Right to Be Forgotten
Mandatory erasure of content from media archives
Automatic anonymization of individuals involved in public matters

Journalistic archives in the U.S. are typically considered public record and protected under strong freedom-of-press doctrines, especially the First Amendment.

3.3. Our Hybrid Compliance Model

Because we operate in both systems, City Pescara News applies the following principle:

Whenever EU law provides higher protection than U.S. law, EU law prevails internally for all processing performed by the European legal entity that owns the platform.

For the publication itself, which is American, editorial decisions fall under U.S. press freedom, but personal-data handling—collection, storage, technical processing, communication—remains governed by EU standards.

4. Confidentiality in Editorial Interactions

City Pescara News ensures that communications between readers, sources, journalists, and editorial staff are treated as private and confidential unless explicitly stated otherwise. We operate under the following conditions:

When a source requests anonymity, it is preserved to the maximum extent allowed by U.S. and EU law.
When an individual submits a correction or clarification, it is processed according to GDPR accuracy requirements.
When materials are submitted for review, publication is never automatic; editorial filters apply.
When an individual claims reputational harm, we evaluate the request under EU data-protection standards and U.S. editorial-freedom principles simultaneously.

Confidential information submitted for legal review, correction, or clarification will never be published without consent, except in circumstances where disclosure is required by law, court order, or essential public interest.

5. Protection of Personal Data

Because we operate under European rules, all personal data processed by City Pescara News is treated according to GDPR standards, even if servers or editorial offices are physically located in the United States.

5.1. Types of Data We Collect

Identification data (e.g., name, email, IP address)
Voluntary submissions (statements, files, documents)
Technical data (cookies, session information, analytics)
Communication data (emails, requests, correction forms)

We do not collect:

Financial information
Health data
Biometric identifiers
Any sensitive information unless voluntarily provided and strictly necessary

5.2. Lawful Basis for Processing

We process data based on:

Consent
Legitimate interest
Contractual necessity
Journalistic exemption permitted under EU law

5.3. Data Security

All data is protected by:

Encrypted storage systems
Two-factor authentication
Access-limited internal protocols
Secure backup architecture
Real-time monitoring and threat-prevention systems

5.4. Cross-Border Transfers

Any transfer of personal data from the EU to the U.S. is done through:

Standard Contractual Clauses (SCCs)
Technical safeguards ensuring data cannot be accessed unlawfully
Minimization of stored data to the strict minimum

6. The Right to Be Forgotten and Editorial Immunity

The EU’s Right to Be Forgotten (Right of Erasure) does not exist in the United States. American law strongly protects:

Historical truth
Public interest
Media archives
Free speech
Journalistic independence

Because City Pescara News is an American publication, we must clearly state:

Content published for journalistic purposes is not automatically deletable from our archive.

However, because our company is EU-based, we voluntarily provide a hybrid system:

6.1. When You May Request Erasure or Anonymization

We consider requests for:

Proven inaccuracies
Outdated information that no longer serves the public interest
Cases involving minors
Sensitive personal circumstances
Reputational harm unrelated to criminal activity
Cases where the individual was acquitted or rehabilitated
Court-validated privacy claims

6.2. When We Cannot Grant Erasure

We cannot remove content when:

It concerns public figures acting in public capacity
It involves judicial or criminal matters still relevant to public safety
U.S. press freedoms prohibit alteration of archival materials
The information is accurate and historically important
Erasure would compromise journalistic integrity

6.3. Editorial Discretion

All decisions are made individually, balancing:

Public interest
Accuracy
Historical value
Reputational harm
Legal obligations
Ethical journalism standards

7. Confidentiality for Corporate, Legal, and Government Communications

Communications received from:

Law firms
Government offices
Corporate representatives
Public institutions
Investigative bodies

are treated with the highest confidentiality standard.

We will never:

Publish private legal documents without explicit authorization
Disclose the identity of confidential legal representatives
Reveal sensitive government communications unless public interest requires it

If a communication is expressly labeled “CONFIDENTIAL — NOT FOR PUBLIC RELEASE”, it will be treated as strictly confidential.

8. Confidentiality for User-Generated Submissions

Users may submit:

Articles
Comments
Corrections
Photos
Videos
Testimonies
Requests for anonymity

City Pescara News guarantees:

No private user submission will ever be disclosed
No identifying elements will be shared without consent
Comments may be pseudonymized upon request
Sensitive uploads are never published without explicit approval

We reserve the right to remove, edit, or moderate any content that violates legal or ethical standards.

9. Confidentiality of Investigative Material

Investigative journalism requires strong protection mechanisms. Therefore:

All investigative documents remain encrypted and access-restricted.
Identities of whistleblowers and informants are protected.
Sensitive material is never transmitted via unsecured channels.
Cross-border investigative requests are handled according to EU and U.S. law simultaneously.

10. Data Retention Policy

We retain:

Editorial materials indefinitely, as U.S. law allows
Personal data only for the minimum time required
Confidential materials only as long as necessary for journalistic or legal purposes

Data retention schedules are aligned with GDPR principles.

11. Your Rights Under GDPR (Even on an American Newspaper)

Because our company is subject to EU law, YOU retain your full GDPR rights, including:

Right of access
Right to rectification
Right to restriction
Right to object
Right to data portability
Right to request anonymization
Right to request review of editorial decisions (non-binding but considered)

Requests may be sent to our official Data Protection Contact.

12. No Waiver of Rights

Using our website does not constitute:

Waiver of your EU rights
Consent to share your data
Permission for third-party access
Authorization for repurposing content

All rights remain fully protected.

13. Confidentiality in Internal Staff Operations

All employees, collaborators, freelancers, and editors must:

Sign strict confidentiality agreements
Follow EU-aligned privacy protocols
Undergo annual training
Maintain strict separation between public and private data

Any violation results in disciplinary and legal consequences.

14. Disclaimer on U.S. Press Freedom

City Pescara News is protected under:

U.S. First Amendment rights
State journalism laws
Federal communications regulations

This means:

We cannot be compelled to alter truthful reporting
We cannot suppress information of public interest
We cannot modify historical archives without cause

However, we evaluate each privacy request with fairness and European sensitivity.

15. Contact for Confidentiality and Privacy Requests

Data Protection & Confidentiality Office – City Pescara News
Email: confidentiality@citypescara.news
Alternate contact available upon request.

All communications will be treated privately and answered with transparency.