PROTECTION OF YOUR PERSONAL DATA
Processing operation: Management of Safer Internet Day (SID) Committee and Supporter Group and Safer Internet Centres (SICs and SICs+) networks and their subscriptions to receive information on SID in the context of the BIK project.
Data Controller: European Commission, Directorate‑General for Communications Networks, Content and Technology (CNECT), Unit G3: Accessibility, Multilingualism and Safer Internet (hereinafter “Unit G.3”).
Data Processor: EUN partnership aisbl (hereinafter “European Schoolnet”), Rue de Trèves, 61 (3rd floor), 1040 Brussels, Belgium.
Record reference: DPR-EC-03928
1. Introduction
The European Commission and EUN Partnership aisbl (hereinafter referred to as European Schoolnet or the data processor/contractor) are committed to protect your personal data and to respect your privacy. The Commission and European Schoolnet collect and further process 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.
This privacy statement explains the reason for the processing of your personal data for network management and campaigning purposes, within the Safer Internet Day (SID) supporters group and committee and the Safer Internet Centres (SICs and SICs+) networks, by European Schoolnet on behalf of Unit G.3.
It explains 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 Controller (Unit G.3) 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
“Management of the SID Committee and SID Supporter Group and Safer Internet Centres (SICs and SICs+) networks and their subscriptions to receive information” undertaken by European Schoolnet on behalf of Unit G.3, is presented below.
2. Why and how do we process your personal data?
Purpose of the processing operation: European Schoolnet collects and further processes your personal data, on behalf of the European Commission, so that you can receive information that you have requested, as SID supporter or SID committee member and SICs or SICs+ network member, on campaigns such as the Safer Internet Day campaign and on tasks required to administer or manage your group or network.
Your personal data will not be used for an automated decision-making including profiling.
In order to manage the SID supporters’ group and SID committee and the SICs and SICs+ networks, as well as their related subscriptions to receive information, European Schoolnet is inviting all relevant stakeholders to submit information through online forms in EUSurvey. The aim of the forms is as per the below.
European Schoolnet collects data from the SID Committee members to update their profile pages for the Safer Internet Day (SID) campaign. SID profiles could be published on the public portal area of the Better Internet for Kids (BIK) platform or https://better-internet-for-kids.europa.eu/en/saferinternetday. Committee members give consent for their first name, last name and email addresses to be published on the BIK platform as well as kept for internal reporting and communication purposes; including to receive information they requested on activities and campaigns such as the Safer Internet Day Campaign.
European Schoolnet collects data from SIC+ country representatives to manage and administer the SIC+ activity line, and create SIC+ profiles potentially viewable on the public portal area of the Better Internet for Kids (BIK) platform or https://better-internet-for-kids.europa.eu/en/saferinternetday All representatives give consent for their first name, last name and email address to be published on the BIK platform and/or to be kept for internal reporting and communication purposes; including to receive information they requested on activities and campaigns such as the Safer Internet Day Campaign. SIC+ country representatives may also wish to submit SID profile information (in keeping with the information for SID Committee members above).
European Schoolnet collects information from Safer Internet Centres (SICs) to manage and administer the SICs networks and the Better Internet for Kids project; including public profile data needed to create and update SIC profiles viewable both within the closed community area and public portal area of the Better Internet for Kids (BIK) platform and on https://better-internet-for-kids.europa.eu/en/saferinternetday. All Safer Internet Centre contacts give consent for their first name, last name and email addresses to be on the BIK platform and/or to be kept for internal reporting and communication purposes; including to receive information they requested on activities and campaigns such as the Safer Internet Day Campaign or Positive Online Content Campaign. SIC representatives may also wish to submit SID profile information (in keeping with the information for SID Committee members above).
The online forms to collect your data are sent using the Commission's online questionnaire tool EUSurvey. A local instance of Mailman which European Schoolnet has installed on its own servers may be used to create and configure mailing lists. Some mailings may be sent using Newsroom, the mailing and newsletter management tool linked to the Commission.
3. On what legal ground(s) do we process your personal data?
We process your personal data, because you have given your consent to the processing of your personal data for the purpose of receiving the requested information.
Your consent concerns the following actions:
• if applicable and you opted for this option, the sharing of your first name, last name and email address on the Better Internet for Kids (BIK) platform and on https://better-internet-for-kids.europa.eu/en/saferinternetday.
• the processing of your personal data for the purpose of managing and administering your group or network (i.e. SID Committee, SID supporters’ group, SIC+ and SIC networks).
• the processing of your personal data for the purpose of receiving information you have requested on activities such as campaigns; including the processing of your personal data as supporter of the Safer Internet Day campaign to enable its practical organisation.
If you opt in, you are giving us your explicit consent under Article 5(1)(d) of Regulation (EU) 2018/1725 to process your personal data for those specific purposes. You can give your consent via a clear affirmative act by ticking the box(es) on the online registration form.
Your consent for these services can be withdrawn at any time by notifying Unit G.3 (and European Schoolnet).
4. Which personal data do we collect and further process?
In order to carry out this processing operation, the following categories of personal data may be collected:
Your contact details (title, first name, last name, contact email address, job title, organisation name) to ensure you are kept informed.
Furthermore, you may spontaneously provide other, non-requested personal data in the free text fields of the forms used.
Please note that the European Commission does not request or expect that data subjects provide any special categories of data under Article 10(1) of Regulation 2018/1725 (that is “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person’s sex life or sexual orientation”) related to themselves or to third persons in their contributions to the targeted consultation activity. Any spontaneous inclusion of these types of personal data is the responsibility of the data subject and by including any of these types of data, the data subject is considered to provide his/her explicit consent to the processing, in accordance with Article 10(2)(a) of Regulation 2018/1725.
5. How long do we keep your personal data?
We only keep your personal data for the time necessary to fulfil the purpose of collection or further processing, namely until you ask to be removed from the contact list or unsubscribe from the mailing list.
You can write to the dedicated functional mailbox and ask to be unsubscribed/removed from the contact or mailing list. Appropriate action shall be taken within a week of receiving the request. Please write to support@betterinternetforkids.eu.
In case data is kept for statistical purposes, some subscriber's optional data may be kept for 5 years after the un-subscription, providing these do not allow to identify the subscriber any more and that these are available to a very restricted number of authorised persons performing the processing operation on a “need to know” basis, for the sole purposes of generating anonymised statistics.
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of data, etc.) are stored on European Schoolnet servers on behalf of the European Commission. 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.
In order to protect your personal data, the Commission has put in place a number of technical and organisational measures. 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.
Additionally, European Schoolnet, as the Commission’s contractor, is bound by a specific contractual clause for any processing operations of your personal data on behalf of the Commission. Therefore, it has put in place the appropriate technical and organisational measures to ensure the level of security required by the Commission.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to European Schoolnet’s authorised staff involved in the administration and management of the Safer Internet Day campaign, the SIC networks and the SID Committee. Access to your personal data is also provided to the Commission staff involved in this processing operation as well as to other authorised Commission staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
No publication of personal data is foreseen except for the specific actions described in Section 3 for which we are asking explicit consent.
Online forms to collect your data may be sent using EUSurvey (the Commission's online questionnaire tool). Mailings and newsletters may be sent using Newsroom (mailing and newsletter management tool linked to the Commission). The Processing of your data in EUSurvey and Newsroom is aligned with the current record of processing activities DPR-EC-03928.
Third-party IT tool – mailing management
Mailman may be used to create and configure mailing lists. A number of mailing lists have been put in place using a local instance of Mailman which European Schoolnet has installed on its own servers. As such personal data collected and processed do not leave the European Schoolnet infrastructure.
Third-party IT tools – social media
European Schoolnet uses third-party IT tools to communicate about and promote campaigns such as the Safer Internet Day campaign through widely used communication channels, including various European Schoolnet social media accounts (e.g. X (formerly Twitter), Facebook, LinkedIn).
Videos uploaded on our social media pages or on video-hosting platforms may be embedded on our website(s), and you may be able to view such a content. In order to protect your privacy, our use of third-party IT tools to connect to those services does not set cookies when our website pages are loaded on your computer (or other devices), nor are you immediately redirected to those social media or other platforms. Only in the event that you click on a button or “play” on a video to watch it, a cookie of the social media company concerned will be installed on your device. If you do not click on any social media buttons or videos, no cookies will be installed on your device by third parties.
You may also be able to follow links from European Schoolnet’s or the Commission’s website(s), or our communications to our social media pages or other relevant social media. In order to view such third-party content, you need to accept those third parties’ specific Terms and Conditions, including their cookie policies, over which the Commission and European Schoolnet have no control. We recommend that users carefully read the relevant privacy policies of the social media tools used. These explain each company’s policy of personal data collection and further processing, their use of data, users' rights and the ways in which users can protect their privacy when using those services. The use of a third-party IT tool does not in any way imply that the European Commission or European Schoolnet endorses them or their privacy policies. In the event that one or more third-party IT tools are occasionally unavailable, we accept no responsibility for lack of service due to their downtime.
International Transfers
Your information is not intended to be transferred to destinations outside of the EU/EEA, although it may be accessible to parties outside of the EU/EEA via websites.
The information we collect will not be given to any other third party not mentioned in this statement, except to the extent and for the purpose we may be required to do so by law.
Please note that pursuant to Article 3(13) of Regulation (EU) 2018/1725 public authorities (e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients. The further processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
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. 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.
In line with information provided in Section 3, you have consented to provide your personal data for a number of specific processing operations. You will be able to withdraw your consent at any time by notifying Unit G.3 (and European Schoolnet). The withdrawal of your consent will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can also 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 in Section 9 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 Section 10 below) in your request.
9. Contact information
The Data Processor/Contractor
For any questions or concerns about this privacy statement or the processing of your data, you can contact the Data Processor: EUN Partnership aisbl (European Schoolnet) at privacy@eun.org. Your questions will be transferred to Unit G.3 if necessary. You can also contact Unit G.3 directly.
The Data Controller
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 Data Controller, Directorate-General for Communications Networks, Content and Technology (Connect), Unit G3 Accessibility, Multilingualism and Safer Internet (CNECT-G3@ec.europa.eu).
The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) 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 European Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-03928.