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Notification Regarding the Processing of Personal Data of Participants in Language Competence Examinations

Pursuant to the application of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Hellenic American Union (22 Massalias Street, 10680 Athens) (the “HAU”) would like to inform you of the following:

1.         What data is processed by the HAU belonging to which natural persons: The HAU, in its capacity as data controller, processes personal data of the following persons (“data subjects”): (a) adults who participate in language competence examinations organized by the HAU; and (b) minors that participate in language competence examinations and which are being represented by holders of the parental responsibility or the guardianship. Data processed by the HAU may include (a) personal information (e.g. full name, father’s name, gender, date of birth, phone number (home/ mobile), e-mail address, signature, image, examination center, type of the language competence examination in which the data subject participates and the date on which the examinations are being conducted, data of the data subject’s examiner, the Foreign Language Center at which the participant in the language competence examinations is studying, ID number, date of issuance and the issuing authority or passport number and date of its issuance/ expiration, etc.); (b) special categories of data, if applicable, such as health-related data that the data subject may disclose for special arrangements to be made for his or her participation in the language competence examination (e.g. special learning difficulties, other health issues.); and (c) financial data relating to the payment of fees to the HAU in the context of the data subject’s registration in the language competence examinations, such as bank card information, bank account numbers, billing and payment data etc. The disclosure of the data specified in subparagraphs (a) and (c) above is a legal or contractual obligation of the data subject or a requirement to conclude a contract. Where the data subject does not provide the above data or part thereof, he or she will not be able to register and therefore, participate in the language competence examinations organized by the HAU.

2.         Source of data: The source of the data, as the case may be, is the data subject himself/ herself disclosing his/ her data or the holders of the parental responsibility or the guardianship of the data subject, Foreign Language Centers, English language teachers or/ and examination bodies. To the extent that the persons mentioned above transmit third party personal data to the HAU, they shall be responsible for complying with the applicable provisions of the data protection legislation. In this context, they may need to obtain the data subjects’ consent before transmitting data to the HAU.

3.         Purpose and legal basis of processing data: The HAU processes data subjects’ personal data, as the case may be, for the following purposes: (a) to register, provide services and in general manage the participants in the language competence examinations, to release the examination results and check the certificates which are being issued for them. For such data processing, the legal basis shall be the performance of the relevant contract concluded with the HAU and compliance with a legal obligation of the HAU (e.g. the HAU’s legal obligation to verify to public authorities that language competence examination certifications have been issued in the name of their employees), while for special categories of data (as specified in clause 1 (b) above) that may have been disclosed to the HAU, the legal basis for processing shall be the data subject’s relevant consent given by the disclosure of the relevant personal data to the HAU and the protection of the vital interests of the data subject or of another natural person where the data subject is incapable of giving consent. (b) To safeguard the interests of the HAU. For such data processing, the legal basis is that processing is necessary for the purposes of the legitimate interests pursued by the HAU which override the interest, fundamental rights and freedoms of the data subject which require the protection of personal data (e.g. for the establishment, exercise or support of legal claims, in which case the processing, if necessary, will also extend to specific categories of data). (c) To send marketing material via electronic mail. It should be noted that the HAU is entitled to use the data subjects’ electronic mail contact details, lawfully obtained in the context of the provision of its services or any other transaction, for the direct promotion of similar services or for the furtherance of similar purposes, even where data subjects have not given their prior consent, provided that they are given, when contact details are collected, as well with every message, a clear and transparent option to object, easily and free of charge, to the collection and use of their electronic data. For such processing of data, the legal basis is that processing is necessary for the purposes of the legitimate interests pursued by the HAU (i.e. the legitimate interests relating to the promotion of its services), which override the interest, fundamental rights and freedoms of the data subject which require the protection of personal data.

4.         Recipients of data: As the case may be and depending on the purpose of processing, personal data may be transmitted to the authorized employees in each department of the HAU, to companies associated with the HAU with which the HAU has a concluded a contract and which process the data on its behalf (e.g. IT companies, IT service providers, etc.), within their competencies and subject to the obligation of confidentiality, secrecy and compliance with the data protection legislation, to Foreign Language Centers or/ and English language teachers. In addition, the HAU in the context of the data processing purpose mentioned in the term 3 (a) above and depending on the type of the language competence examination, may transmit data subjects’ personal data to examination bodies. In particular, with respect to personal data transfers outside the European Economic Area and where the examination body of the language competence examinations is: (a) the Cambridge Assessment English, personal data are being transmitted to the Cambridge Assessment English established in the UK (The Triangle Building, Shaftesbury Road, Cambridge, United Kingdom, CB2 8EA), (b) the Hellenic American University, personal data are being transmitted to the Hellenic American University established in the USA (436 Amherst Str., Nashua, NH 03063); and (c) the Cambridge Michigan Language Assessment LLC (CaMLA), personal data are being transmitted to the Cambridge Michigan Language Assessment LLC (CaMLA) established in the USA 535 West William Str., Suite 310, Ann Arbor, Michigan 48103-4978). For the purpose of transferring data to the USA, the HAU has signed with these examination bodies standard contractual clauses for the protection of the personal data, that have been adopted by the European Commission and are considered to provide sufficient guarantees for the lawfulness of the data processing. If a data subject wishes to receive a copy of the standard contractual clauses that have been put in place, he/ she may contact the Data Protection Officer of the HAU using the contact information mentioned in the term 6 below. 

Finally, the HAU may transmit personal data to third parties where so required by law (e.g. obligation of the HAU under the applicable legislation to verify to public bodies that language competence examination certifications have been issued in the name of their employees), or for the purposes of, or in connection with legal proceedings in which it participates, or otherwise for the purposes of supporting, exercising or defending its rights, or to third parties that are law enforcement authorities and have submitted a lawful transmission request, or where it considers that transmission is necessary in connection with any investigation into the suspicion or existence of any illegal activity.

5.         Data retention time:

The above data will be retained for a period time as required or allowed by the legislation/regulatory framework in force each time, taking into account the applicable prescription period, which may extend to up to 20 years. Specifically: (a) where processing is carried out under a relevant contract, the personal data shall be stored for as long as necessary for the performance of the contract and for the establishment, exercise and/or support of any legal claims of the HAU arising from that contract; and (b) where the processing is imposed as an obligation by provisions stemming from the applicable legal framework, personal data shall be stored for as long as the relevant provisions so require. Finally, personal data included in the language competence certification, may be retained, exclusively for the purpose of data subjects’ interests, for sixty (60) years.

6.         Data subjects’ rights:

The data subject shall have the following rights under the GDPR: (a) to receive a copy of the personal data held by the HAU, together with other information on how data is processed; (b) to request that personal data concerning him or her be rectified and, under conditions, to request the deletion or restriction of processing, or to object to the processing of personal data; (c) to receive a copy or to request the transmission of a copy of his or her personal data to a third party in a structured, commonly used and machine-readable format (right to data portability). Where the processing of data is based on his or her consent, the data subject shall have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. If the data subject wishes to receive further information about the processing of his or her personal data or to exercise any of the aforementioned rights, he or she must email the HAU Data Protection Officer at: privacy@hau.gr, or send a letter to the mailing address mentioned above. Finally, the data subject has the right to file a complaint with the competent supervisory authority about how the HAU handles his or her data (www.dpa.gr). 

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