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Data protection policy

Object of the Data Protection Policy:

Fræðslunetið places emphasis on confidentiality and security when it comes to processing personal information in its operations. This Data Protection Policy is intended to explain what information is collected, how it is used and what access is granted to it. This policy is intended to promote the common understanding of all those who use Fræðslunetið’s services as well as those who work for Fræðslunetið, sit on its Board of Directors or work as contractors on its behalf. This Data Protection Policy is based on the provisions of Act No. 90/2018 on the Protection of Personal Privacy and Processing of Personal Data and ESB Regulation No. 2016/679 (GDPR) on the protection of individuals with regard to the processing of personal data and on the freedom of movement of such data. The policy applies to all services provided by Fræðslunetið and to all parties who are clearly working on its behalf.

Fræðslunetið’s operations:

Fræðslunetið is a continuous education centre located on the south coast of Iceland and operates as such in the following areas:
• Service provider on behalf of the Education and Training Service Centre (ETSC). Provides educational and vocational counselling, handles skills assessment and conducts secondary education in connection with the certified curriculum of the Education and Training Service Centre.
• Service provider on behalf of Fjölmennt Adult Education Centre. Provides training for adults with disabilities.
• Service provider on behalf of the Icelandic Centre for Research (Rannís). Provides teaching in Icelandic as a second language for immigrants.
• Service provider on behalf of VIRK Vocational Rehabilitation, Birta Vocational Rehabilitation of South Iceland and the Directorate of Labour (VMST). Provides resources and training courses for people in vocational rehabilitation.
• Provides companies with various services in the form of education, consultancy and analysis.
Fræðslunetið is a not-for-profit organisation owned by numerous NGOs, municipalities and companies in the south of Iceland. Fræðslunetið has a service agreement with the Education and Training Service Centre, operates in accordance with the Act on Continuing Education No. 27/2010 and is a recognised education provider from the Ministry of Education, Science and Culture.

Collection and use of personal information at Fræðslunetið:

All processing of personal data by Fræðslunetið is conducted for clear purposes and on legitimate grounds, in accordance with the Act on the Protection of Personal Privacy. Fræðslunetið places great importance on taking the processing of personal data no further than necessary.
Personally identifiable information is data that is used directly or indirectly to identify or contact a specific person. Any information which is not personally identifiable is not deemed to be personal data.
New privacy laws include strict requirements for the handling of sensitive personal information. Examples of sensitive personal information are medical condition, religion, trade union membership, sexual orientation and ethnic origin. Under certain circumstances, Fræðslunetið collects sensitive personal information due to its operations.

Fræðslunetið processes the following personal information:

• Personally identifiable information: name, ID number, e-mail address, telephone number and address
• Information on trade union membership
• Criminal record information
• Information on medical conditions
• Information on gender
• Payment card information
• Information on education / education level
• Information on attendance / attendance in course
• Information on correspondence with Fræðslunetið
• Technical information on how Fræðslunetið’s webpage is used: IP address, language settings, browser settings, time zone settings, etc.
• Geographical information: geographical position
Fræðslunetið uses and processes personal information for the following purposes:
• To provide clients with answers on previous studies at Fræðslunetið
• To process applications for learning/education
• To carry out a skills assessment
• For operational purposes: send out accounts, pay contractors and receive payments via credit card.
• To book and carry out interviews with vocational and career advisors
• To keep track of attendance, grades, learning processes and publish testimonials upon completion of studies. Such information is entered and stored in INNU.
• Due to personnel administration
• Due to the hiring of contractors for teaching jobs
• For marketing purposes

Informed customer and employee consent:

Processing of certain personal information is necessary when customers register for services with Fræðslunetið. The registration of individuals for courses is through Fræðslunetið’s website, where they check the declaration that they have read the Privacy Policy of Fræðslunetið. Anyone seeking counselling, risk assessment or company training is introduced to the Privacy Policy. Employees and contractors of Fræðslunetið confirm with their signature that they have familiarised themselves with the policy.

Website and social media:

Fræðslunetið collects various information concerning website security, such as the IP addresses of users. The site also uses cookies that collect information about activity, visitor frequency and more. Users of the website will receive a pop-up where they are invited to accept such processing.
Fræðslunetið uses social media to disseminate news on its operations and to advertise its services. If personally identifiable information such as pictures are published, the consent of the person in question is requested beforehand.
Personal information shared with third parties:
In certain circumstances, Fræðslunetið needs to share personal information with third parties. Such situations may come about due to contracts with stakeholders, requests from public entities, contractor work for Fræðslunetið, the hosting of digital data in data centres, litigation and due to laws and regulations.
Fræðslunetið ensures that personal information is not provided to a third party unless a processing agreement is in place between the party and Fræðslunetið on how to process the relevant information.

Storing personal information:

Because of its activities, Fræðslunetið must preserve a range of personal information in accordance with the Act on Continuing Education No. 27/2010. Likewise, Fræðslunetið maintains a variety of personal information relating to employee administration, information disclosure to the Ministry of Education and other summaries of data for marketing and developmental purposes. Personal information is stored electronically in the INNU database, electronically in Microsoft and 1984 data centres and in print format in locked storage.
Rights of the individual:
Under the Privacy Act, individuals have the right to access the personal information that is stored about them. In some cases, they may also be entitled to correct, forward or delete their personal information.

Queries:

If Fræðslunetið receives questions, complaints or comments regarding the Privacy Policy or data processing, the matter is followed up by the Director and/or the Data Protection Officer.

Privacy Policy updates:

This Privacy Policy is part of Fræðslunetið’s Quality Manual and is regularly reviewed. Changes to the Privacy Policy may be announced without notice.

First Issue 18 November 2018