The Interdisciplinary Centre for Law, Alternative and Innovative Methods (“ICLAIM or the Centre”) (registration number HE 366376) is committed to respecting privacy when dealing with personal information collected by ICLAIM, in accordance with the EU General Data Protection Regulation 2016 (the “GDPR”).
The scope of this policy covers the below mentioned processing activities involving personal or sensitive data where the Centre acts as controller.
The following personal information ICLAIM collects and uses accordingly, namely:
|Name, Email, Email Content||Enquiring information about ICLAIM||Legitimate interests; be able to respond|
|Name, Email||Subscriptions to email updates and newsletters||Consent; only once consent is obtained|
|Name, Consumer complaint content, Payment details, Forms of identification, Country of residence, Contact address, nationality, Email and Phone number||Submitting a complaint to the ADR entity||Consent; only once consent is obtained Legitimate interests; be able to respond and activate dispute resolution|
|Name, Email, Affiliation, Country of residence, Payment details and/or Phone number||Registration to activities or events||Consent; only once consent is obtained Legitimate interests; be able to activate participation to activity or event|
|Name, Profile, Photo, Country of residence, Email and/or phone number||Signing Up as member of the Social Mediators Network (contact list, what’s app group, mobile app)||Acceptance; by accepting a membership, a network relationship involving communication tools and platform is activated|
|Name, Profile, Photo, Country of residence, Email, and/or Phone number||Becoming a Resident Expert, a Researcher or an Intern||Appointment; by accepting the relevant appointment, a relationship of Resident Expert, Researcher or Intern with ICLAIM is activated|
|E-learn environnement (Zoom, MS T, etc)||Respective functionality of basic use||Legitimate interests; to be able to deliver expected functionality of basic use|
|Mobile application||Application Functionality||Legitimate interests; to be able to deliver expected functionality|
|Website Activity (cookies)||Website Functionality||Legitimate interests; to be able to deliver expected functionality|
All processing activities shall be based on the following principles:
- Collected for specified, explicit and legitimate purposes only
- Accurate and, where necessary, kept up to date
- Retained only for as long as necessary
- Processed lawfully, fairly and in a transparent manner
- Processed securely, in an appropriate manner to maintain security
- Adequate, relevant and limited to what is necessary
Moreover, ICLAIM will only use collected data in a manner that is appropriate considering the basis on which that data was collected, as set out in the table above.
Examples include the use of data to reply to enquiries sent to ICLAIM, to send news updates where this has been consented to, any other relevant activity connected with the Centre’s activities, etc. No personal data will be shared with third parties unless an explicit consent has been provided by the individual or when ICLAIM is using a third party purely for the purposes of processing data on ICLAIM’s behalf and there is a data processing agreement in place, with that third party that fulfils ICLAIM’s legal obligations in relation to the use of third party data processors.
ICLAIM takes the principles of data minimisation and removal seriously and has internal policies in place to ensure that only the minimum amount of data for the associated purpose is requested and that data is promptly deleted once it is no longer required. Where data is collected on the basis of consent, ICLAIM will seek renewal of consent at least every three (3) years. Where removal of consent is desired, information per project and activity may be found in the corresponding consent form and can be activated.
Regarding cookies, i.e. small files of letters and numbers that are downloaded on to a person’s device when visiting a website, these are used by many websites, e.g. remembering a person’s preferences, recording what a person has put in his/her shopping basket, or counting the number of people looking at a website. Where cookies are used to collect personal data, the Centre lists these purposes in the table above.
However, ICLAIM may also use some cookies that do not collect personal information but that do help the Centre collect anonymous information about how people use the Centre’s website. For this purpose, Google Analytics is used. Google Analytics generates statistical and other information about website usage by means of cookies. The information collected by Google Analytics about usage of ICLAIM’s website is not personally identifiable. The data is collected anonymously, stored by Google and may be used to create reports about website usage.
All those in scope of the policy are responsible for adhering to the requirements of this policy and provide periodic reporting to the board of directors of the Centre on its compliance with this policy.
This Policy is subject to all the laws, rules and regulations that the Centre is governed by. In the event this policy allows the exercise of discretion, such discretion must be exercised within the confines of the Centre’s statutory obligations and shall not contravene any of its legal, accounting or other regulatory requirements.