EDUCOLINA ASSOCIATION manages personal data in accordance with the General Regulation on data protection no. 679/2016 in force in the European Union (GDPR). EDUCOLINA ASSOCIATION processes personal data of employees, potential and current students, as well as parents or legal representatives, in the daily activities of providing educational services.
For this purpose, EDUCOLINA ASSOCIATION acts as a personal data operator, establishing the purposes and means of processing personal data according to the specific activities in the education process.
"Processing" means any operation performed on personal data, whether or not automated means are used, such as collection, registration, storage, adaptation, modification, consultation, use, disclosure by any means, deletion or destruction.
1. Why we process personal data:
EDUCOLINA ASSOCIATION processes personal data belonging to you as candidates, employees, students or parents for the following purposes:
- Providing educational services, starting with the admission process, enrolling students, class and schedule administration, teaching activities in their own and online spaces, managing internal and public exams, issuing enrolment registers and academic evaluation reports;
- Providing complementary educational services: personal development and counselling, access to the school library, extra-curricular activities, excursions, school publications, as well as the creation of a virtual learning environment;
- Ensuring security on campus: monitoring access to campus, video surveillance, ensuring security in online education sessions;
- Providing medical assistance and psychological counseling in case of need;
- Ensuring the mandatory safety measures imposed by the authorities to return to education conditions at school campus, as well as to ensure the hybrid education system, in accordance with the Framework Methodology announced by the Ministry of Education and Research in September 2020;
- School administration: management of students' educational files and documents, management of students' and parents' contact lists (telephone, e-mail), management of invoices and payments, internal audits and controls, elaboration of reports and statistics, implementation of school policies, ensuring collaboration with other schools, archiving, evaluating the quality of our services, facilitating research activities;
- Communication in school: sending messages about students and educational activities through secure means of communication, including communication for the smooth running of distance activities and online school;
- Settlement of disputes.
2. The categories of personal data we process include, but are not limited to, the following:
- Information and contact details (name and surname, citizenship, country of origin, address, information included in the IC / passports, CNP, Birth Certificates, telephone number, e-mail, etc.);
- Bank details;
- Medical documents: medical record at registration, medical history, allergies, vaccination record, diseases, results of medical examinations and other medical documents of students;
- Data on the educational environment and academic performance of students: academic results and semester assessment reports, discipline and conduct of students, hobbies, results of educational tests, teacher feedback, etc.
- Data on students 'discipline and conduct, as well as data on students' preferences / interests;
- Data on email addresses, IP addresses and other personal items associated with the online distance education system;
- Family data: information about siblings enrolled in the EDUCOLINA ASSOCIATION, household, linguistic history, profession and place of work of parents, etc.
- Authentication and identification data: e-mail, passwords, campus access card, location data, other online identification details, personal auto information, etc.
- Photos and videos;
- Images recorded by the video surveillance system, which in the absence of notable incidents are automatically deleted after 30 days.
In general, the personal data we hold were provided to us directly by parents or as a result of the interaction between school, parents and students. In some cases, the data was provided by third parties (for example, by transferring the school record or by representatives of the schools where the students previously studied).
3. The legal basis of personal data processing operations
EDUCOLINA ASSOCIATION collects and processes personal data based on one of the following legal reasons, in accordance with GDPR requirements:
Consent given before the processing of personal data, for:
- Use of photos and videos with students in different school publications, on the website of the EDUCOLINA ASSOCIATION and on the official social media pages;
- Use of contact details for marketing messages about the charitable actions organized by the EDUCOLINA ASSOCIATION;
- Other agreements that may be required periodically for various personal data processing activities.
- To sign and comply with the Schooling Contract, starting with the steps to start the admission process and continue to benefit from our educational services.
Please note that there are several categories of mandatory personal data required to conclude the Schooling Contract and to provide educational services at high standards and in the interest of students. These are included in the Application Form completed online and attached to the schooling contract that you have concluded / are to conclude with the EDUCOLINA ASSOCIATION. All categories of mandatory data for the conclusion of the contract are marked accordingly in the Application Form, being necessary to assess the application and register the child in the new school year. Failure to complete all the information marked as mandatory in the form makes it impossible for us to enrol your child with us and to conclude a schooling contract.
- A legislative provision that requires us to process certain categories of personal data (eg identification and contact data for the billing of education services).
- In order to fulfil a task of public interest, given that we offer educational services considered services of public interest, in accordance with the provisions applicable in the field of education in Romania, many data processing operations performed strictly for educational purposes will have this legal basis for processing. Examples would be the issuance and storage of documents with academic results, evaluation of student performance, etc.
- The legitimate interest pursued - we rely on this legal basis to provide the educational services for which we are committed and complementary services to the highest standards, always for the benefit of students and without violating the rights and freedoms of parents or students.
We can use the legitimate interest as a legal basis in the following situations:
- Monitoring the use of the virtual learning environment and the network, including monitoring the use of the e-mail account provided by the EDUCOLINA ASSOCIATION;
- Organizing fundraising activities, including promoting these activities;
- Execution of legal claims, resolution of complaints and control of third parties;
- Managing, controlling, reporting and compiling statistics on school activity;
- Ensuring security at school premises, including through video monitoring systems;
- Maintaining close relations with the parents' community;
- Collaboration with other schools and educational institutions;
- Collaboration with the organizers of domestic and international events, including online events;
- Access to grants and other sources of funding.
Regarding the processing of special categories of personal data, we may process medical information based on the following legal reasons:
- The medical office processes such data for prevention and occupational health programs, for the diagnosis and provision of medical or social care or treatment based on European or national legislation;
- Evaluating a student's learning ability and adapting teaching activities to his individual needs, according to the public interest of ensuring equal educational activities;
- Disclosure of personal data related to allergies or various chronic diseases suffered by a student, based on the consent of him and his parents;
- Processing of special personal data of students and employees for reasons of vital interest, absolutely normal in emergency and alert conditions: data on the history of interaction with Covid-19 contaminants, data on possible symptoms associated with Coronavirus, data on possible chronic diseases from Occupational Medicine centres, family doctors or by completing questionnaires on their own responsibility;
- Psychology teachers can have access to a number of sensitive personal data related to a certain psychological profile, the existence of files of children and the current activities of psychological consultations.
4. Disclosure of personal data
Your personal data is disclosed only to EDUCOLINA ASSOCIATION employees, staff and collaborators who need access to personal data to provide educational and complementary services. In this regard, we assure you that only the medical office has access to students' medical records and data.
With regard to the disclosure of your personal data to third parties, please note that the transmission of data takes place only in the day-to-day activities of the school, and the categories of recipients include the following:
- IT service providers, including educational applications, online learning tools, direct marketing platforms or information management systems;
- Travel agencies, catering and transport service providers;
- Other kindergartens or schools by transferring schooling files;
- Other educational institutions or organizations, which are not limited to other schools;
- Organizers of extra-curricular events, including online events;
- Providers of remote communication and collaboration platforms used in online school sessions;
- Photo and video teams contracted by EDUCOLINA ASSOCIATION;
- Courier service providers;
- Utility service providers;
- Public authorities and institutions, national or international courts and foreign embassies or other types of diplomatic missions;
- Tax, legal and accounting consultants.
5. Transfers to third countries
We may transfer the personal data of students and parents to a third country only for the purpose of participating in school activities, trips or international camps that are the subject of the activity of our institution. From 2021 January 1st all transfers of personal data to our partners in the UK are legally justified by the post-Brexit GDPR adequacy agreements between the EU and the UK.
For any other situation, EDUCOLINA ASSOCIATION will ask for your prior consent.
6. Storage of personal data
EDUCOLINA ASSOCIATION stores all your personal data while you are in a contractual relationship with the school, and subsequently, within the maximum period established by law for each category of personal data. EDUCOLINA ASSOCIATION keeps the students' files and all the data regarding the student's interaction with EDUCOLINA ASSOCIATION mainly in order to evaluate the school activity and the quality of the offered services, but also to respond to the potential requests of the students regarding their educational path.
Please note that all enrolment records and other school documents related to study activities are kept for an indefinite period, in accordance with the legal obligations of the EDUCOLINA ASSOCIATION in this regard. In addition, all documentation related to tuition contracts and financial aspects (invoice records, payroll of employees) comply with the minimum retention period required by applicable national law.
7. Your rights regarding the processing of personal data by EDUCOLINA ASSOCIATION
GDPR provides all data subjects (employees, students, parents, partners) with a series of rights related to access to personal data. According to this policy, EDUCOLINA ASSOCIATION respects all access rights required by GDPR as follows:
- The right to access personal data, by the possibility of obtaining confirmation whether or not your personal data are processed by EDUCOLINA ASSOCIATION, as well as additional information such as: purpose of processing, categories of recipients to whom personal data are disclosed and the period provided storage;
- The right to rectification, which allows you to request the rectification by the EDUCOLINA ASSOCIATION of any incorrect personal data or to complete incomplete personal data;
- The right to delete data or the “right to be forgotten”, which we can exercise only in situations expressly regulated by law, where personal data are no longer necessary in the current processing, there is no legal obligation or contractual to condition their retention or when the processing is based on a consent that is withdrawn.
- The right to restrict processing, which means your right to obtain restrictions on the processing of your personal data. And this right can only be exercised in specific situations established by the GDPR, such as when you challenge the accuracy of your personal data;
- The right to data portability, which implies your right to receive personal data in a structured, frequently used and electronically accessible format and to pass this data on to another operator;
- The right to oppose the processing of your personal data by the EDUCOLINA ASSOCIATION, for reasons related to your particular situation;
- The right to file a complaint is the right to notify the manner in which the EDUCOLINA ASSOCIATION performs the processing of your personal data to the competent authority for data protection: the National Authority for the Supervision of Personal Data Processing (ANSPDCP) or to any legal authority;
- The right to withdraw your consent for various personal data processing operations, in cases where the consent is the legal basis for processing. In the event that you opt to withdraw a previously agreed agreement, please note that processing will be terminated from the moment we submit the request, without affecting the processing that took place before the request for withdrawal of consent was sent.
In any case in which you need to exercise any of these rights, please contact the EDUCOLINA ASSOCIATION and officially send us the request by filling in the Form for requesting access to personal data and sending it to the contact addresses of down. EDUCOLINA ASSOCIATION has developed a procedure for solving access requests, through which we have all the necessary resources to ensure the answer to any request considered justified, within the legal term of 30 days and under the conditions stipulated by GDPR.
8. Creating educational profiles
EDUCOLINA ASSOCIATION can create and use educational profiles to assess students 'performance, to identify gaps in their development or to assess specific traits that characterize students' personality, preferences, and behaviour or professional inclinations.
9. Video surveillance
EDUCOLINA ASSOCIATION has implemented a video surveillance system to ensure the safety of students, staff and all others who have access to campus. The safety and security of our students is our main concern and these video cameras allow us to offer real-time protection. All measures taken to ensure the security and confidentiality of recorded video images are set out in the Video Surveillance Policy.
10. Contact person
In the event that you wish to exercise any of the rights listed in point 7 or to obtain additional information or clarifications regarding the processing of your personal data, please send your request to the email address [email protected] and you will receive the access rights request form. The answer to the request sent through this form will be endorsed by our data protection specialist.
Contact details of the personal data protection specialist EDUCOLINA ASSOCIATION:
Email address: [email protected]