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PROTECTION OF YOUR PERSONAL DATA

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

Processing operation:  EU International Partnerships Academy

Data Controller:  Directorate-General for International Partnerships, Human Resources, Learning Development and Document Management (hereinafter NTPA.R1)

Record reference:  DPR-EC-00541

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 Commission (hereafter ‘the Commission’) is committed to protect your personal data and to respect your privacy. The Commission collects 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 Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.

The information in relation to processing operation the EU International Partnerships Academy undertaken by Directorate-General for International Partnerships (DG INTPA) – Unit INTPA.R1 is presented below. 

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

Purpose of the processing operation: Directorate-General for International Partnerships (DG INTPA) – Unit INTPA.R1 collects and uses your personal information to ensure the functioning, management and promotion of the information and learning platform called EU International Partnerships Academy.

In particular, data is collected and processed for the following specific purposes:

to monitor/manage information on courses (incl. participation, activity, completion)

to communicate with participants (notifications)

to generate certificates for the completion of a course

to provide access to restricted courses intended only for EU staff

to monitor the number of users registered on the INTPA Academy

to generate learning analytics

The processing of the personal data is based on the voluntary registration of the user concerned.

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 processing of personal data for the purposes of the EU International Partnerships Academy is lawful according to Article 5(1)(a) and (d) of Regulation (EU) 2018/1725. 

We process your personal data, because processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body, according to Article 5(1)(a) of Regulation 2018/1725. In particular, as far as European Commission (EC) staff is concerned, Article 24a of the Staff Regulations provides as follows: “The Union shall facilitate such further training and instruction for officials as is compatible with the proper functioning of the service and is in accordance with its own interests. Such training and instruction shall be taken into account for purposes of promotion in their careers”.

Furthermore, the Learning and Development Strategy adopted by the Commission on 24 June 2016 (Communication C(2016) 3829 final) lists among the Commission-wide learning priorities: “Helping all staff understand the role, main policies and challenges of the Commission, as well as the concerns of Member States and other Institutions. This should help staff to explain policies and make connections between their work and the bigger picture”. 

Finally, this is in line with INTPA. Unit R1 mandate, as stated, in its mission statement: “The Unit contributes to and follows-up on knowledge management-related initiatives at Commission level and with other development organisations, in particular the multi-donor network Learn4Dev. The Unit manages the newly constituted "EU International Partnerships Academy”.

Moreover, we process your personal data because you have given your consent to us, under Article 5(1)(d) of Regulation (EU) 2018/1725, to the processing of his or her personal data for one or more specific purposes. In this regard, concerning the fields marked as “optional”, as well as for external registered users (non-EC staff), consent is obtained for the processing of their data via a clear affirmative act when registering to the EU International Partnerships Academy. Data subjects have to tick boxes declaring: “I hereby consent to the processing of my personal data for the purposes of the EU International Partnerships Academy as detailed in the specific privacy statement.”

Concerning INTPA Academy newsletter, individual subscription is optional via Newsroom and requires consent:

"By checking this box, I confirm that I want to register for this service and I give my consent to the European Commission to process my personal data for the purpose described in the privacy statement (that is, to receive information requested on different topics in the area of (a) service(s) of the European Commission through our newsletter or notifications)."

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

In order to carry out this processing operation Directorate-General for International Partnerships (DG INTPA) – Unit INTPA.R1 collects the following categories of personal data:

Mandatory user profile data:

Name

Surname

Email address

Country

City

Type of organisation

Organisation

Users may also include additional (optional) information under their profile, including:

User (avatar) picture

Picture description

(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:

First time/date of access to platform

Last time/date of access to platform

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

The EU International Partnerships Academy uses cookies to make sure the platform works properly. For more information on the use of cookies you can consult our cookie policy https://ec.europa.eu/info/cookies_en.  

5.          How long do we keep your personal data?

Directorate-General for International Partnerships (DG INTPA) – Unit INTPA.R1 only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing, namely for training services of the INTPA Academy.  Personal Data along with the user account/profile will be kept on the platform as long as the account is active and there was no request made by the user to remove him from the platform.

Users are considered active when they have registered, completed mandatory profile data, and checked the Terms and Conditions to be considered active.

Users are considered inactive following two (2) years of continuous inactivity.

Users can request to have their account / profile deleted at any time by contacting the INTPA Academy team via the functional mailbox intpa-academy@ec.europa.eu (Data is not kept anywhere and/or in any form after deletion of any account.)

Inactive user accounts will be deleted from INTPA Academy after a period of two years of inactivity. Every two years an email will be sent to verify if the user wishes to continue or not the registration on the platform. The user has a month to reply or reactivate the account. After one month, a reminder will be sent, and the user will have 15 days to either ask for deletion of the account or reactivate it. Without users' reply, the account / profile will be permanently deleted. (Data is not kept anywhere and/or in any form after deletion of any account.)

For the future, the INTPA Academy team intends to implement an automatic feature to detect inactive user accounts. In case of inactive user accounts, after 2 years of continuous inactivity and following an un-replied e-mail notification from the administrators of the platform, the user account will be deleted, along with the profile and personal data provided.

The period of retention of data will also depend on the period of validity of the EU Login of the INTPA Academy registered users. For more information, you may consult the EU Login specific privacy statement (and corresponding Record DPR-EC-03187 “Identity & Access Management Service (IAMS)”).

Personal data for the purposes of the EU International Partnerships Academy newsletter is kept in Newsroom as long as administrators of INTPA Academy continues the news alert service - unless a subscriber removes their subscription or asks to be unsubscribed by requesting it in a separate mail to intpa-academy@ec.europa.eu

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

Personal data is stored on the servers of the European Commission according to the general IT security policy and measures in force in the 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 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 to the platform is restricted via EU login, who implements its own safeguard mechanisms to ensure a secure access. Further details are available via their Privacy statement: users registered with the European Commission's Identity and Access Management Service (IAMS) (DPR-EC-03187)

In 2023 a security plan assessment was carried out in collaboration with governance and security. The security requirements for the INTPA Academy are currently sufficiently mitigated by the existing security measures and the highest Residual risk level is 2.0 in a scale of 1 to 50.

As the hosting partner, DG DIGIT also offers multiple services to analyse and monitor security risks, including application vulnerability assessments (AVA). Such reports consider both manual and automatic scenarios that identify any security risks, suggesting how to remedy them.

Other mechanisms include those set up by DG DIGIT and its IT infrastructure. Moodle itself is part of DG DIGIT authorized applications. In addition, Moodle is an open source LMS that is supported by an active worldwide community, including an active developer community that has multiple security measures in place. The application regularly receives upgrades and patches to ensure a high level of security and stability. To find out more on Moodle’s specific security mechanisms: Security procedures | Moodle Developer Resources

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

Access to your personal data is provided to the Commission staff and authorised consultants of INTPA. Unit R1 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. 

The INTPA Academy team includes members of the European Commission Directorate General for International Partnerships (INTPA), from Unit INTPA.R1 and authorised consultants.

INTPA. Unit R5, 'DevOps team' can access the system's database that contains personal data - however when exports are made, these are done in an anonymous (sanitized) manner to protect personal data.

DIGIT (The Directorate-General for Informatics) is responsible for the infrastructure where INTPA Academy is hosted.

Learning resources such as videos and documents containing personal data (name, username, image and voice of speakers/moderators) are accessible to only INTPA Academy registered users. 

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, rectify or erase your personal data and the right to restrict the processing of your personal data. Where applicable, you also have the right to object to the processing or the right to data portability.

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

You have consented to provide your personal data to DG INTPA. Unit R1 for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.

Users can request at any time to have their profile (containing enrolments, activities and any other data) removed from the EU International Partnerships Academy by sending an email to the Data Controller “DG INTPA. Unit R1”.

As regards the EU International Partnerships Academy newsletter subscription, you can access, modify or delete your personal information in the "Profile Page" which is accessible via the link at the bottom of each newsletter issue or by simply sending an e-mail to the address indicated in the news alert.

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 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 Heading 10 below) in your request.

9. Contact information

-      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:  

•       European Commission Directorate-General for International Partnerships, Human Resources, Learning Development and Document Management Unit R1

•       Phone number: +32 2 2956001

•       E-mail address:  intpa-academy@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 Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dporegister.

This specific processing operation has been included in the DPO’s public register with the following Record reference: DPR-EC-00541.