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|Privacy Notice for the DiTEM platform (Digital Transformation of European Micro-enterprise)||Politiche di privacy||Tutti gli utenti|
|Copyright||Politiche di privacy||Tutti gli utenti|
This privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with data protection legislation.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
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Who we are
The DiTEM partnership is a partnership between Manchester Metropolitan University (UK) as the lead partner, Eurocrea Merchant Srl (IT), CrystalClearSoft (GR), Turku University of Applied Sciences (FI)), Innobridge (BG), Exponential Training & Assessment Ltd. (UK), it-forum (DK). The partnership is committed to protecting the privacy and security of your personal information.
The DiTEM partners are "data controllers". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
What information does the DiTEM partnership collect?
Personal data means any information about an individual from which that person can be identified.
The types of information we collect and hold about you include:
§ personal contact details; your name, title, name of your organisation and email address;
§ correspondence with or about you, for example emails about the completion of online modules or coaching support
The purposes of the processing / why does the DiTEM partnership process personal data?
This section includes an explanation of our lawful basis for processing.
We will only use your personal information where you have provided consent for us to do so. The DiTEM partners will process data to monitor the use of the e-learning platform developed by the DiTEM partners, to offer support in completion of the e-modules, and to ensure that the relevant administrative and evaluation documents related to the training on the platform are completed which will help us to ensure that course content is relevant and effective.
In addition, the DiTEM partnership will:
§ Maintain accurate and up-to-date project beneficiary records and contact details;
§ Operate and keep a record of support provided through and funded by the DiTEM project;
§ Undertake business management and planning, including accounting and auditing;
§ Ensure network and information security and compliance with information and communication policies.
Your personal details will be available to the DiTEM partner based in the country of sign-up, and to the overall administrator, CrystalClearSoft, based in Greece.
Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.
We do not envisage that any decisions will be taken about you using automated means, however we will notify you if this position changes.
Recipients / who has access to data?
The DiTEM platform is hosted by CrystalClearSoft [MV1] who will hold the data collected. For security reasons, data is also stored in a back-up server only accessible by DiTEM partner CrystalClearSoft.
Your name, name of your organisation and your email address is only accessible by the DiTEM partner based in your country of residency. However, it may be shared with other DiTEM project delivery partners, including: Manchester Metropolitan University (UK), Eurocrea Merchant Srl (IT), CrystalClearSoft (GR), Turku University of Applied Sciences (FI), Innobridge (BG), Exponential Training & Assessment Ltd. (UK), it-forum (DK).
We will only disclose information about you to third parties if we are legally obliged to do so or where we need to comply with our contractual obligations, for instance we may need to pass on certain information about you to the relevant funding bodies supporting the partnership and its projects. The DiTEM partnership might also share data with third parties that process data on its behalf, for example auditors or funding body (Erasmus + and its National Agency, the British Council working with Ecorys).
We do not send your personal data outside the European Economic Area. If this changes in the future, you will be notified of this and the safeguards in place to protect the security of your data.
How does the DiTEM partnership protect data?
The DiTEM partnership takes the security of your data very seriously, and has internal policies and controls in place to try and ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. We will only process your personal information on the DiTEM partner’s instructions and they are subject to a duty of confidentiality. For more information, please contact your country’s DiTEM partner (Details in the Contact Us section below).
Where the DiTEM partnership or its lead partner Manchester Metropolitan University ask third parties to process data on its behalf, for example auditors or evaluators, they do so on the basis of written instructions, are under a duty of confidentiality and must ensure that they have appropriate technical and organisational measures in place to keep the data secure.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Data retention / how long does the DiTEM partnership and Manchester Metropolitan University keep data?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, contractual or reporting requirements.
Your personal data will be stored throughout your involvement with the DiTEM project, and for a period afterwards: due to funding requirements, information will need to be retained for a period of 5 years beyond the end of the project, ie until 28th February 2025, or until notified that records can be destroyed.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once project records are no longer required contractually and/or for statutory purposes we will securely destroy your personal information in accordance with our data retention policy.
What if you choose not to provide personal data?
Certain information, such as your name, name of your organisation and your email address, are required to allow you to access the DiTEM e-learning platform to access courses developed by the DiTEM partners. Essential fields are marked by an ‘*’. Other fields are optional, and will not affect your registration.
You have the right to withdraw that consent at any time – the withdrawal procedure can be accessed through the user’s profile, by contacting the privacy and policies officer requesting for your data deletion. This will not affect the lawfulness of processing before your consent was withdrawn.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Data subject rights
As a data subject, under data protection legislation, you have various rights in relation to your personal data. You can:
§ request access to your own data by making an access request – this enables you to receive a copy of the personal information we hold about you and check that we are lawfully processing it;
§ request that we correct any inaccuracies in the data that we hold about you;
§ request that we erase your personal data where we are not entitled by law to process it or it is no longer needed for the purpose it was collected;
§ request that processing of your data is restricted – this enables you to ask us to suspend the processing of personal information about you, for example if you want to establish its accuracy or the reason for processing it;
§ object to processing of your personal information where we are relying on our legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground;
§ request the transfer of your personal information to another party.
If you wish to make an access request or assert any of the rights detailed above, please contact the Data Protection Officer using the contact details below.
Right to lodge a complaint
You have the right to lodge a complaint with the relevant authority of your country of residence (in the UK, the Information Commissioner’s Office (ICO)* is the supervisory authority in respect of the processing of your personal data). We would encourage you to expend your internal complaint procedure initially through the contact of the DiTEM partner of your country of residence (please see below) and/or Manchester Metropolitan University Data Protection Officer, prior to contacting the relevant authority.
For questions or concerns about this Privacy Notice or how we store and use your personal information, please contact the Data Protection Officer of your country’s DiTEM partner in the first instance.
· CrystalClearSoft (DiTEM e-learning platform developer), email@example.com, +30 210 674 6200, or postal address: Katechaki 44, Athens, Greece
· Manchester Metropolitan University (DiTEM lead partner)- firstname.lastname@example.org, +44 (0) 161 247 3884 or in writing to: Data Protection Officer, Legal Services, All Saints Building, Manchester Metropolitan University, Manchester, M15 6BH, United Kingdom
· Eurocrea Merchant Srl - email@example.com, +39 0287284807, or postal address: Via Domenico Scarlatti, 30, Milano, Italy
· Turku University of Applied Sciences, firstname.lastname@example.org +3582263350, or postal address: Joukahaisenkatu 3A, Turku, Finland
· Innobridge Business Innovation Centre, email@example.com, +359889422199, or postal address: Ferdinand 3A, 7000, Ruse, Bulgaria
· It-Forum, firstname.lastname@example.org , +4570222391, or postal address: Aabogade 15, DK-8200, Aarhus, Denmark
*If you wish to contact the ICO the following contact information can be used: email@example.com or telephone: 0303 123 1113. For any further contact information please see: https://ico.org.uk/global/contact-us/.
Changes to this privacy notice
We reserve the right to update this
privacy notice at any time, and we will provide you with a new privacy notice
when we make any substantial updates. We may
also notify you in other ways from time to time about the processing of your