The generalized civic access request, governed by Art. 5, paragraph 2, of the Transparency Decree, allows anyone to exercise the right to access data, information, and documents in addition to those subject to mandatory publication, provided they are held by Invimit and in compliance with the limits set to protect legally relevant interests under Art. 5-bis of the Transparency Decree.

The exercise of the right to generalized civic access is not subject to any limitation regarding the applicant’s legal standing, requires no justification, and is free of charge. Invimit is not required to create, collect, or otherwise procure information that is not already in its possession, nor is it required to reprocess the information it holds, but only to allow access to the information contained in documents resulting from data processing carried out by the Company for its own purposes, in their current state.

How to exercise simple civic access

The civic access request must be submitted to the Anti-Corruption and Transparency Officer (“RPCT”) as established by Art. 5, paragraph 3, letter d) of the Transparency Decree.

The request, duly completed using the specific form (see link below) and accompanied by a copy of the applicant’s identification document, may be submitted in one of the following ways:

• by email to trasparenza@invimit.it;
• by certified email to invimitsgrspa@pec.it;
• by registered mail with return receipt to: Invimit SGR S.p.A., Via Quattro Novembre, No. 144 – 00187 Rome.
  
  

The request is reviewed by the RPCT and processed within 30 days from the date of receipt, with the support of the functions responsible for the publication of the requested documents, based on the Three-Year Anti-Corruption and Transparency Plan.

Invimit, after verifying the existence of the publication obligation, publishes the requested data, documents, or information on the institutional website within 30 days. The RPCT informs the applicant of the publication within the same timeframe, providing the hyperlink.

If the requested data, documents, or information are already published, the RPCT will provide the relevant hyperlink to the applicant.

Denials or limitations of access must be justified by the RPCT, with specific reference to the applicable law and the factual and legal circumstances that prevent the request from being granted as submitted.

In cases of delay or lack of response, the applicant may appeal to the substitute authority, namely the President of Invimit, who, upon verifying the existence of the publication obligation, will act within 15 days of receiving the request.

Appeals against the Company’s decisions regarding civic access may be lodged within 30 days before the Regional Administrative Court of Lazio – Rome, pursuant to Art. 116 of Legislative Decree No. 104 of July 2, 2010 (“Administrative Procedure Code”).