What data will be collected?
Only data that enable the staff of the DIGI-LEARN project partners to perform the tasks specified in the funding agreement will be collected. This applies in particular to training, workshops, conferences and training activities as well as evaluation studies of the DIGI-LEARN project.
Within the DIGI-LEARN consortium, a rigorous discussion was held to limit the amount and type of data collected to a reasonable minimum. These include:
- Personal data (Anonymous. Personal identifiers are kept, as far as possible, separate from other data).
- Structured and unstructured notes taken by researchers, trainers and experts during the project (evidence of participants’ interventions; allows for the smooth transfer of information from one phase to the next).
- Written and oral statements (e.g., in interviews, only with explicit consent).
- Questionnaires and surveys applied for evaluation and quality assurance studies.
- Photographs and video clips (used for (a) the DIGI-LEARN project, (b) personal collection, and for (c) documentation, dissemination and promotion of the DIGI-LEARN project).
Legal basis/legal compliance
In accordance with the General Data Protection Regulation (GDPR), the DIGI-LEARN project collects and processes the described types of user data
- with your consent
- in order to communicate with you and inform you about the DIGI-LEARN project,
- in the legitimate interest of carrying out promotion, dissemination, quality assurance and research activities in accordance with the grant agreement.
A data protection impact assessment is currently being carried out by each of the DIGI-LEARN project partners.
What will happen to the data collected in the DIGI-LEARN project?
All personal data will be pseudonymized and, where possible, anonymized in accordance with the GDPR and the related ethical guidelines established by the DIGI-LEARN consortium. Your data will be indicated by a unique participation number and every effort will be made to keep identifiers such as your name or email address separate. The data will only be available to a small group of employees of the DIGI-LEARN partners who have signed a data protection declaration.
The DIGI-LEARN consortium takes a proactive approach to privacy. We do not use profiling or automated decision-making processes. The organizations of the DIGI-LEARN consortium undertake to treat your personal data as absolutely confidential, using it only for the statutory non-commercial purposes of the DIGI-LEARN project, in accordance with the funding agreement. This applies in particular to the design, conduct and evaluation of training, workshops, conferences and learning processes, as well as evaluation studies of all phases of DIGI-LEARN.
Anonymized research findings will be summarized in project reports, journal articles, presentations and other academic and public research results. Key quotes or findings will always be anonymized in any formal output unless we have prior explicit written permission to attribute them by name.
Photography and video
Whenever individuals can be identified from their image, data protection laws apply. In such situations, the rights of individuals to collect and use their images must be respected: they must be informed when their image is recognized or captured, and a legal basis must be found before the image is used in any way.
Photographs of posed individuals and groups: when you take photos of a specific person that you want to publish on the Internet, you can use “legitimate interest”, “consent” and “contractual obligation” as a legal basis. Remember that consent can be withdrawn at any time and you will have to respond accordingly.
Photos of crowds: if you take photos of crowds at an event and you cannot identify the person, you do not need to have a legal basis for taking, displaying or publishing the photo. This applies to all individuals, students and employees whose images are incidental details, for example, in crowd scenes at workshops, conferences and on campus in general. If the photos are taken at a conference where people are likely to be identified even in crowd scenes, then the legal basis is “legitimate interest”. We control where your photos are used and store them for up to ten years.
How will my data be stored and processed?
The official organizations of the DIGI-LEARN consortium will only store, process and use personal data for the statutory purposes of non-commercial activities within the scope of the DIGI-LEARN project and in accordance with the General Data Protection Regulation (GDPR).
The organizations forming the DIGI-LEARN consortium are implementing specially designed policies to prevent unauthorized or inappropriate access to this information. All raw electronic data will be stored on the password-protected and restricted access DIGI-LEARN platform. Hard copy documents (e.g. signed documents, paper surveys) will be securely stored by a staff member of a DIGI-LEARN partner (specific to your country).
Data Retention
The DIGI-LEARN Consortium will retain raw personal data (e.g., real names, interview recordings) only as long as necessary, i.e., until the end of the DIGI-LEARN project funding period, November 2026.
Properly anonymized and processed datasets will be retained after the end of the DIGI-LEARN project funding period for data sharing – or a similar GDPR-compliant data repository – for future ethically approved research.
Data exchange with third parties
Internal (i.e. within a DIGI-LEARN partner organization) and external (i.e. between DIGI-LEARN partner organizations) data sharing of participants’ personal data is kept to a minimum and is constantly checked for necessity and proportionality and is only carried out for the purpose of fulfilling the non-commercial activities specified in the DIGI-LEARN project funding agreement.
DIGI-LEARN partner organizations use internal and external partners to communicate and promote their activities on behalf of DIGI-LEARN. Therefore, your personal data/image may be shared with partner organizations involved in promoting innovative education. Your image may also be used on third party platforms where the DIGI-LEARN project has a presence. This currently includes Facebook and LinkedIn. If your image is used online, this will inevitably be subject to international data transfer, and we may also share your photo data with agencies (e.g. Facebook) operating outside Europe. If you provide personally identifiable information, we will request your permission to publish this personally identifiable information.
Requests from police or law enforcement agencies: The DIGI-LEARN Consortium is not legally obligated to provide information to the police unless it receives a court order. However, DIGI-LEARN partner organizations often choose to disclose information when the police or other law enforcement agencies can demonstrate that non-disclosure may jeopardize the prevention/detection of a crime or the apprehension/prosecution of offenders.
Data Controller
For data collected in the DIGI-LEARN project, Agis, Note & Innove [ANI] is the data controller (as defined in the EU General Data Protection Regulation (Regulation (EU) 2016/679)).
Who can I contact if I have questions or complaints?
If you have any questions or concerns about your participation in DIGI-LEARN or about the research in the DIGI-LEARN project, please contact Agis, Note & Innove [ANI] (erasmus@ani-international.org).
For general information about Agis, Note & Innove [ANI]’s use and protection of data, please visit: www.ani-international.org.
If you wish to file a formal complaint about the study, please contact Agis, Note & Innove [ANI] at erasmus@ani-international.org. In your communication, please include the title of the project and detail the nature of your complaint.
Accessibility
You can obtain this document in print, Braille, hard copy and various digital formats upon request. To do so, please contact Marta Formato, www.ani-international.org.
Document updates
In the event of changes to DIGI-LEARN that affect the processes described in this Notice to Participants on Security and Breach of Information, this document will be updated and all current DIGI-LEARN participants will be notified.