ENIT
Sign In
← Back to Portal Home

Compliance

Data Privacy &
Data Protocol

PWJ Fiduciary Services adheres to strict European data protection directives while upholding the professional legal privilege inherent in trust administration.

Professional Mandate & Confidentiality Standards

Fiduciary Compliance
Standards

Following the recent Consiglio di Stato ruling, the Italian UBO Register is fully operational. Under D.Lgs. 231/2007, inaction is no longer a viable strategy. We bridge the gap between statutory disclosure requirements and your fiduciary duty to protect party privacy.

Privacy & Fiduciary Confidentiality

Navigating the UBO register requires a careful balance. We ensure your trust meets its disclosure obligations while strictly protecting the privacy of beneficiaries and settlors.

Penalty & Reputation Shield

Failure to disclose triggers significant administrative fines under Art. 21. We identify and resolve historical reporting gaps to safeguard your professional standing and mitigate fiscal risk.

Cross-border Compliance

Managing cross-border compliance through mandatory sworn court translations and Italian Fiscal Code (Codice Fiscale) synchronization.

Remote Management from Abroad

A secure interface designed to manage complex Italian filing requirements entirely from abroad, eliminating the need for local physical presence.

1. Data Controller & Legal Framework

The data controller for all personal information submitted via the Trust Register platform is PWJ Fiduciary Services. All processing activities are executed in strict accordance with the General Data Protection Regulation (GDPR - Regulation (EU) 2016/679) and applicable national enactments governing professional legal secrecy.

2. Purpose and Scope of Processing

Information collected within the intake and assessment pipelines is utilized exclusively for:

  • Determining the existence of reporting obligations under the Italian Ultimate Beneficial Ownership (UBO) register framework (D.Lgs. 231/2007 and D.M. 55/2022).
  • Executing official communications with the Italian Business Register (Registro Imprese) and Chamber of Commerce via certified telematics channels (Telemaco/DIRE).
  • Procuring Italian Fiscal Codes (Codice Fiscale) for non-resident entities and individuals holding reportable positions.

3. Professional Confidentiality vs. Public Disclosure

We act as private administrative liaisons. Data uploaded to our encrypted environment remains strictly confidential. We explicitly reject third-party commercial inquiries and do not execute public access requests under the general "Legitimate Interest" test unless mandated by competent judicial authorities following formal adversarial proceedings.

4. Retention Periods

Client records, sworn translations, and submitted documentation are maintained for the duration required under Italian anti-money laundering frameworks (ordinarily 10 years following the termination of the relationship or completion of the ultimate filing step), after which records are securely purged from our active environments.

5. Rights of the Data Subject

Natural persons identified within the intake flow retain full rights to request access, rectification, erasure, or restriction of processing of their personal data, subject to archiving requirements. Requests may be directed to our Rome liaison desk.