GUIDE

on ensuring the protection of personal data during the Erasmus + Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (“PROMIS”)

 

Carrying out activities through technology and the internet within the PROMIS project requires participants, teachers, students, and collaborators (technical staff) to comply with security measures to ensure the protection of personal data processed[1] on this occasion.

The measures passed in this Guide do not exclude the other IT security measures that each user must adopt.       

The protection of participants’ personal data in online activities must be considered an obligation for all those involved in the process; respect for this fundamental right prevailing over adopting methods that may be associated with intrusion into people’s privacy and implicitly violating a fundamental right.

1. 1.     What types of personal data will be processed through the Platform (MOODLE) https://course.promis.education/?

            For the purposes of EU Regulation 2016/679 on the protection of personal data (GDPR) and Law 190/2018 on the implementation of the GDPR (see the definition of personal data Art. 4(1) [2]), the following will be collected types of personal data:

Personal Data	Purpose of processing	Processing means	Legal basis
Name, Surname	- account creation - identification in the Platform	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
E-mail Address	- validation of the account registration to the Platform - notifications regarding Trainers’ feedback and points obtained - communication with Trainers and other peers - password recovery	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
Username and Password	- private connection to the platform - course enrollment and identification	Sign-Up form	Consent (Art. 6 (1) (a) of the GDPR)
IP	- identification – temporary storage	Automated collection	Consent (Art. 6 (1) (a) of the GDPR) Cookies Policy
University, Subject of study program	- enrollment to training programs - assessment of activities within the Platform	Profile editing	Consent (Art. 6 (1) (a) of the GDPR)

 

1. 2.     Why is personal data collected through online education platforms?

The https://course.promis.education/ platform developed through technology and the internet is part of the Erasmus + Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (“PROMIS”) (no. 2019-1-RO01-KA203-063157). The project contract is concluded between UBB as project coordinator and the National Agency for Community Programs in the Field of Vocational Education and Training. UBB has as partners the University of Bologna (Italy), the University of Bordeaux (France), Cardinal Stefan Wyszyński University of Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands), SC eLearning & Software SRL Arad (Romania).

For the good development of the project, the project coordinator, UBB and its partners adopted a series of technical and organizational measures to facilitate the access of the target group members to the educational resources and the planned online activities.

3. How are personal data processed?

- participants will register for the Platform using the online form inserted in the website https://course.promis.education/, providing the name, surname, e-mail address, user, and password to access the Platform;

- teachers will be enrolled on the Platform by …(describe the procedure)

- based on the completion of the form and the granting of the consent regarding the processing of personal data, the participants will receive a confirmation on the e-mail address provided;

- participants will enter the MOODLE platform using the username and password chosen by themselves;

- after accessing the MOODLE platform, the participants will complete their profile by providing the name of the institution to which they belong and the field of study of interest;

- participants can choose whether or not to display the e-mail address so that it is visible to other enrolled participants; it is also optional to provide additional information;

- the MOODLE platform allows the visualization of personal data provided by participants as follows:

            - the members of the project team from Babes-Bolyai University and of SC eLearning & Software SRL Arad (Romania) will be able to view all the data provided to ensure a good technical perspective operation of the Platform https://promis.education

            - teachers who organize training activities will view the name, surname, and learning activities that participants have accessed.

- the Platform will store personal data to allow subsequent access to the Platform and resumption of activities. The retention period is eight years from the project’s start date, the 4th of November 2019;

- the participants can make use of the rights they have, including the right to withdraw their consent, which will determine the cessation of processing from that moment.     

           

4. Recommendations:

- the provisions of the other regulations regarding the development of the project will be observed;

- steps will be taken to use a secure internet connection and workstation.  

 

5. The following restrictions shall be taken into account:

- the username or password to connect to the Platform cannot be communicated/transmitted/disseminated to other persons;

- no personal data of the other participants in the project will be collected and disseminated by any person regardless of how they came into their possession;

 

6. Are personal data transferred?

The personal data collected within PROMIS are processed by UBB together with SC eLearning & Software SRL Arad (Romania), the administrator of the MOODLE platform https://promis.education as an associated operator.

Some of the personal data collected are accessible to teachers from the University of Bologna (Italy), the University of Bordeaux (France), Cardinal Stefan Wyszyński University in Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands).

The transfer of personal data is based on the contract concluded between the Babes-Bolyai University and the stated partners.

In accordance with Regulation (EU) 2018/1725 on the protection of individuals with regard to the processing of personal data by EU institutions, bodies, offices and agencies and on the free movement of such data, part of personal data is transferred to:

Head of Unit B4

Directorate B - Youth, Education and Erasmus +

General Directorate of Education, Youth, Sports and Culture

The European Commission

B-1049 Brussels

Belgium

and,

The National Agency for Community Programs in the Field of Vocational Education and Training

Splaiul Independenței no. 313, UPB Central Library, building A,

060042 Bucharest

Romania

7. Obligations of beneficiaries and partners regarding GDPR

SC eLearning & Software SRL Arad (Romania) will establish technical and organizational measures as well as the necessary procedures to avoid the collection of accidental or illegal personal data, preventing the unauthorized dissemination of these data.

Beneficiaries University of Bologna (Italy), University of Bordeaux (France), Cardinal Stefan Wyszyński University of Warsaw (Poland), Kaunas University of Technology (Lithuania), Utrecht University (Netherlands) will establish technical and organizational measures to ensure the protection of data staff of the participants.

Note:

            Regarding the protection of personal data of participants in the Erasmus + Strategic Partnership project “Promoting social inclusion skills in a post-truth world: A gamified online platform and curriculum” (“PROMIS”) (no. 2019-1-RO01-KA203-063157), this Guide is supplemented by the Declaration of Consent signed by the participant, General information on data processing with personal character of Babeș-Bolyai University https://www.ubbcluj.ro/ro/politici/ and the Policy on the use of cookies on the project website https://course.promis.education/ administered by SC eLearning & Software SRL Arad (Romania).