Data Protection Policy

Collection of Personal Data

The MDigi-I Consortium as the Data Controller collects Personal Data from you within the purposes of research and the project’s scope. So, in the following cases:

When you contact us directly or indirectly (e.g. through the project’s webpage and/or e-mail, or through our partners, or through our Social Media pages, etc.), in order to be informed regarding the Project or ask for relevant information;

If you fill in any of our documents or subscribe to our newsletter;

The MDigi-I Consortium may also publish video or photographs of images in case of events or workshops, provided that the relevant data subject gave its consent to the publication of it. There is no transfer of this personal data to third parties outside the same MDigi-I Consortium.

Minors’ Personal Data

We do not collect or process minors’ personal data without verifiable parental consent in cases when we are able to control it. For example, it is not possible to control information that is communicated to us online. In any event, if we find that we have collected any personal information from a minor without verifiable parental consent (in accordance with Article 8 of the Regulation), we will immediately delete the information from our records. If you believe we may have collected information from a minor, please contact us.

Categories of Data Subjects

The categories of data subjects include:

Partners of the Consortium.

Users visiting the project website.

Social Media users.

MDigi-I platform users.

General Public

Kind of Personal Data we may collect about you

Data from the following categories of personal information about you may be collected and processed per case in order to serve the purpose of the data collection and in accordance with the relevant legal basis as described in this Policy:

Contact details with you or a natural person you may indicate instead of you (name, surname, address, telephone or fax number, email);

Occupational information (occupation, position);

Incident investigation data, such as incident details, data of persons involved or related information;

Information required by the institutional framework such as personal data of persons depended on or related to our Consortium members;

Apps/websites/social media-related data (cookies, full name or nickname, information you publicly disclose and comments on social media, or email attachments);

Your picture when attending our events, or your photo is uploaded on our social media or website and of course in both cases under your consent.

Purposes of Processing & the Legal Basis of Data Processing

The processing of personal data is based on one of the “legal bases” as referred to in Article 6 of the Regulation (or Article 9 in case of special categories of personal data). The legal basis on which the collection and processing of personal data is based (in most of the cases) are, the consent, the compliance in performing our contractual obligations, the compliance with our legal and statutory obligations, and the safeguarding our legitimate interests. For special categories of personal data, the explicit consent, the performance of obligations and the exercise of specific rights of the controller or data subject in the field of labour law and social security/social protection law and for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment. The legal basis, on which the processing of your personal data is based, is as follows for each processing purpose:

Consent: when you communicate with us in any way directly or indirectly as interested in our project, when you fill in our documents, when informing you about our findings in the context of our dissemination activities, when you make a complaint or statement or when assessing us, when participating in our events, when you visit our social media accounts, or when you give us your business card.

Commitment to perform our contractual obligations: when you have agreed to receive our newsletter.

Compliance with our legal obligations: to comply with our legal obligations to all sorts of authorities such as labour law, regulatory authorities, tax, accounting, auditing, judicial authorities and agencies or in connection with our contractual obligations or during payment of our liabilities.

Safeguarding our legitimate interests: to improve our services, or when investigating and managing any potential incident, or for the assessment of persons and situations.

The Consortium is informed about the processing purposes and the legal bases under specific documents internally.

Retention of Data Period

We store personal data for as long as it is required by the respective processing purpose and any other permitted linked purpose always within the project’s scope on completion of the project the data shall be stored for a period of 5 years after the completion of the project and in accordance to requirements by the European Commission.

Cookies are stored depending on their nature as you may be informed in our cookies policy linked to the present policy (please see below).

Personal data you disclose to us as users are stored for until the completion of the project.

Data that may be needed for our legitimate interests as a Controller shall be kept until the reason for storing such data ceases.

Specifically, for the data we process based on your consent (as an example for marketing), these are kept from obtaining the consent until it is revoked or there is no longer need to store it.

Information that is no longer necessary is safely destroyed or anonymised. We limit access to your personal data to those partners who need to use it for the specific purpose.

How we ensure the security of Personal Data

We have received reasonable organizational and technical measures to protect the personal data we collect, and in particular any specific categories of personal data. We follow international standards and practices to ensure the security of our networks. We ensure you that your personal data is processed securely and legally, by adhering to policies and developing and implementing procedures in accordance with the purposes and legal bases of processing. For example, the following security measures are used to protect personal data against unauthorised use or any other form of unauthorised processing:

Access to personal data is restricted to a limited number of authorised partners as per project structure and under the Data Management Plan and Ethics requirements.

Our repository system of Microsoft Teams, used for the processing of personal data, all technical measures are taken to prevent loss, unauthorised access or other illegal processing.

In addition, access to these Information Communication Technology systems is monitored on a permanent basis in order to detect and prevent illegal use at an early stage. Although the transfer of data through the Internet or a web site cannot be guaranteed to be protected from cyberattacks, we work to maintain physical, electronic and procedural security measures to protect your data.

Some of the security measures we take are not announced for obvious reasons.

To whom the Data may be disclosed

We take measures to ensure that the recipients of personal data are kept to a minimum. The personal data we collect are disclosed to third parties, provided that the legality of such disclosure is fully justified. Specific personal data from those we lawfully collect as a Controller, may be accessed (or disclosed) on a case-by-case basis by:

Any relating supervisory authority within its role;

Any public or judicial authority where required by law or judicial decision.

The auditor of the company, for necessary data according requirement (financial, employment, contracts and other controls), under confidentiality.

The advocate, for whatever data is required in legal cases, under confidentiality.

The Insurance cooperating company and only for the relevant part of the information.

Partners’ banks (of the company, the staff or affiliates and suppliers), only for payment related data.

The training or systems consultants, the trainer, for training or systems control issues and only for the necessary pieces of information and data.

Territorial Scope

The personal data we collect is processed within the European Economic Area (EEA).