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EUVP My Alumni Privacy Statement

PROTECTION OF YOUR PERSONAL DATA

This privacy statement provides information about the processing and the protection of your personal data.

 

Processing operation: EUVP Alumni Platform dedicated to the former participants of the European Union Visitors Programme (EUVP)

Data Controllers: European Commission, Service for Foreign Policy Instruments, Unit FPI.5 & European Parliament, Office of the Secretary General, EUVP Unit

Record reference: DPR-EC-03428.1 for the European Commission and 431 for the European Parliament

 

Table of Contents:

  1. Introduction
  2. Why and how do we process your personal data?
  3. On what legal ground(s) do we process your personal data?
  4. Which personal data do we collect and further process?
  5. How long do we keep your personal data?
  6. How do we protect and safeguard your personal data?
  7. Who has access to your personal data and to whom is it disclosed?
  8. What are your rights and how can you exercise them?
  9. Contact information
  10. Where to find more detailed information?

 

1. Introduction

The European Union Visitors Programme (hereafter, ‘EUVP’) is jointly managed by the European Commission (Service for Foreign Policy Instruments) and the European Parliament (Office of the Secretary General). The EUVP Unit is composed of staff from the two EU Institutions and the day-to-day management of the programme and of the EUVP team is ensured by a Head of Unit from the European Parliament. In light of the above information, the European Commission and the European Parliament act as joint controllers in relation to the functioning and management of the Alumni Platform and are hereafter collectively referred to as the ‘Joint Controllers’.

The Joint Controllers are committed to protect your personal data and to respect your privacy.

The Joint Controllers collect and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).

This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controllers with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.

The information in relation to the processing operation “EUVP Alumni Platform dedicated to the former participants of the European Union Visitors Programme (EUVP)” undertaken by the joint controllers is presented below.

Please note that a separate privacy statement covers the processing undertaken in relation to the “Selection of participants and implementation of the European Union Visitors Programme”.

2. Why and how do we process your personal data?

Purpose of the processing operation: Your personal data is processed in the context of the EUVP Alumni Platform. The Alumni Platform is an online platform dedicated to the former participants of the European Union Visitors Programme (EUVP). Registration to the platform is purely voluntary.

The EUVP Unit collects and uses your personal information to ensure the registration to, functioning and management of the Alumni Platform. In particular, processing of personal data is necessary in order to allow you to become part of the Alumni Platform community, to access to message functionalities, to connect with like-minded alumni, receive the email alerts for notifications. Being a member of the community of users will equally allow you to publish news, events and inspiring information, as well as to contribute to the exchange of ideas and best practices with EUVP Alumni from all over the world.

To complete registration on the platform, users must indicate a set of mandatory information (the detail of which is listed in section 4 of this privacy statement). Additional optional information can be indicated by the user at registration process. Please note that not replying to optional field will not put you in any disadvantaged position. All data can be modified at later stage, on the “user setting” section of the website.

Master administrators of the site can view the e-mail and username through the backend administration panel. Access to these details may be necessary to provide troubleshooting. The password is never visible, and remains encrypted, even for those who manage the infrastructure and development of the platform. The system collects additional data that is visible to administrators of the platform; this information includes: last time/date of access, successful login attempt, failed login attempt

This data provides an understanding of authenticated activity on the website, and allows the identification of inactive accounts. 

Your personal data is submitted by you on a voluntary basis to create your profile on the Alumni platform. Only the minimum necessary data is made obligatory during the registration: first name, last name, country and organisation. Submission of any further data is optional.

Your personal data will not be used for an automated decision-making including profiling.

3. On what legal ground(s) do we process your personal data?

The EUVP was established by the “Reglementation administrative pour l’année 1974 du Comité de direction du programme communautaire d’invitation de ressortissants américains” in 1974 following a resolution of the European Parliament. The role of EUVP is to explain and promote EU values tocitizens of third countries and strengthen long-term bilateral relations between the EU and the respective third countries. This role is also attained by the creation of an external network of contacts for the EU Institutions. This objective of the programme is reflected in articles 3(5) and article 21(1) subparagraphs one and two of the Treaty of the EU.

Article 3(5) of the Treaty of the European Union, states that “in its relations with the wider world, the Union shall uphold and promote its values and interests(…)”. Article 21(1) subparagraphs one and two of the Treaty of the European Union, which state that “The Union’s action on the international scene shall be guided by the principles which have inspired its own creation, development and enlargement, and which it seeks to advance in the wider world(…)” and “The Union shall seek to develop relations and build partnerships (…) which share the principles referred to in the first subparagraph”

For these reasons, processing of your data in the context of the EUVP Alumni Platform is necessary for the performance of a task carried out in the public interest (article 5(1)(a) of Regulation (EU) 2018/1725). In particular, processing is necessary for the functioning of the platform, which aims at the continuous engagement with the EUVP alumni after the end of their programme.

Additionally, your consent is obtained for processing of your data in the context of the Alumni Platform (art. 5(1)(d) of Regulation (EU) 2018/1725).

4. Which personal data do we collect and further process?

In order to carry out this processing operation, we collect the following categories of personal data:

  • Mandatory data: First name, family name, organisation, country of residence, email address
  • Optional data:
    • City, date of participation in the programme, function, phone number, picture, further profile information ("Description of yourself"), areas of interest, social media (Facebook and/or Twitter) account address. 
  • Account data: log-in mail address/password.
  • Data related to the activity of the user: log-in/log off time.
  • User-uploaded/created data: content or files (images, text, videos, information about yourself such as  stories or events visible to other Alumni) uploaded, edited or created by the user,
  • Private messages sent between Alumni.

Account data, data related to the activity of the use and private messages are not publicly available on user profiles. Master administrators of the site can view the e-mail and username through the backend administration panel. Access to these details may be necessary solely to provide troubleshooting.

5. How long do we keep your personal data?

We only keep your personal data for the time necessary to fulfil the purpose of processing, namely the registration to, functioning and management of the EUVP Alumni Platform.

  • Your personal data is kept as long as your account on Alumni platform remains active;
  • You can delete your account at any time by editing your account and choosing the “cancel account” option, available at the bottom of the page or by contacting the platform’s admin – the EUVP unit at euvp@ec.europa.eu; Deleting your account will result in immediate deletion of your personal data from the platform. This includes all content created by the user (publications or else) and past activities. All user data will be deleted from server immediately following deletion of the account (back-ups will be kept for 35 days and system log items will be kept for maximum one week).
  • In case your account remains inactive for 1 year and 2 weeks, your account will be automatically deleted. Before that, you will receive three email notifications by e-mail requesting you to resume activity and informing you about the deletion of your account in case of inactivity. Such email notifications will be sent i). after 6 months of inactivity, ii). after 1 year of inactivity, iii). after 1 year and 1 week of inactivity. In case the user has not been active after 1 year and 1 week of inactivity, he/she will receive an email notification, informing that the data will be erased within one week.

6. How do we protect and safeguard your personal data?

All personal data in electronic format are stored on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.

The Commission’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Commission, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.

In order to protect your personal data, we have put in place a number of technical and organisational measures in place. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.

Authentication of the EUVP Alumni platform is handled by EU Login. When a user wishes to log in the EU Login module checks if they are already logged in via EU Login and if not, the user is being redirected to the EU Login site. The user’s password is stored only on the EU Login system. EU Login is using a two-factor authentication. The user’s username, full name and email are stored both on EU Login and the EUVP platform.

7. Who has access to your personal data and to whom is it disclosed?

Access to your personal data is provided to the European Commission and European Parliament staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.

Specifically, recipients of your personal data are the following:

  • Staff members of the European Union Visitors Programme unit (European Commission and  European Parliament staff).
  • ESN is acting as a service provider/data processor, contracted by the European Commission. ESN is contractually bound to process personal data on behalf of and in line with the instructions of the controller.
  • Other users registered on the platform (EUVP Alumni and officials of the EU institutions). In this group there are two further categories:
  1. Users with whom you exchanged connection requests (your “network”) who have access to all the information you provided in your profile and content-uploaded data
  2. Users with whom you have not exchanged connection requests (“other Alumni”) who have access only to limited information included in your profile: first, last name, function, organisation, picture, interests, short description of yourself.

By default, your personal mail address is not visible to other users.  Your Personal data (both mandatory and optional) are not visible beyond of the community of user.  Master administrators of the platform can view the e-mail and username through the backend administration panel. Access to these details may be necessary to provide troubleshooting.  The password is never visible, and remains encrypted, even for those who manage the infrastructure and development of the platform.

The system collects additional data that is visible to administrators of the platform; this information includes: Last time/date of access, successful login attempt, failed login attempt. This data provides an understanding of authenticated activity on the website, and allows the identification of inactive accounts.

Registered users of the platform who have access to personal data in your profile are based in countries outside the EU/EEA (EUVP Alumni). Transfers of your data to EUVP Alumni based in third countries is necessary for important reasons of public interest. Specifically, such transfers are necessary in line with the provisions mentioned under Chapter 3, considering that by default the EUVP is addressed to citizens based outside the EU/EEA.

8. What are your rights and how can you exercise them?

You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725, in particular the right to access your personal data and to rectify them in case your personal data are inaccurate or incomplete. Concerning accessing your data, you also have the possibility to receive all the submitted data upon request by contacting the administrator of the platform. your data by c. Where applicable, you have the right to erase your personal data, to restrict the processing of your personal data, to object to the processing, and the right to data portability.

You have consented to provide your personal data to the EUVP Unit for the present processing operation. You can withdraw your consent at any time by notifying the joint controller at EUVP@ec.europa.eu or by deleting your account or specific data published in the platform at any time. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.

You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation.

You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 11 below.

Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 12 below) in your request.

9. Contact information

- The Data Controller(s)

If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the joint controllers at EUVP@ec.europa.eu

- The Data Protection Officer (DPO) of the Commission and the European Parliament

You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) of the Commission and/or the Data Protection Officer (Data-Protection@europarl.europa.eu) of the European Parliament with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.

- The European Data Protection Supervisor (EDPS)

You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (edps@edps.europa.eu) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.

10. Where to find more detailed information?

The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the Commission register via the following link: http://ec.europa.eu/dpo-register. The European Parliament public Register is accessible via the following link: https://www.europarl.europa.eu/data-protect/index.do

This specific processing operation has been included in the EC DPO’s public register with the following Record reference: DPR-EC-03428.1 and in the European Parliament public register with the following Record reference: 431.