Personal Data Protection
CIC processes its current and potential clients’ personal data in compliance with the requirements of the Regulation of the European Parliament and of the Council (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR). CIC acts as data controller.
The service of professional social counselling and the social activization services are provided to clients on condition of anonymity or after collecting their personal data. We only process the data that under the circumstances is
essential for providing the social service in question. Our clients can remain anonymous or provide incomplete information. CIC does not check whether the information provided is accurate. Personal data is required in these circumstances:
- When we work with clients’ documents (drawing up a document that contains personal data, such as a letter, a CV, an appeal, a request, etc.) which then are stored electronically.
- When at the client’s request we work with a public institution or other third party.
- When the information about client’s legal status in the Czech Republic is required for the purposes of counselling.
- When in order to provide counselling services, it is necessary to keep the client’s contact details.
The legal grounds for the processing of clients’ personal data are a verbal contractual obligation to provide a social service and the provider’s legitimate interests (reporting statistics on the organization’s performance to show the fulfillment of the obligation to provide certain social services and of the terms of regional subsidies received). The personal data we process includes:
For those interested in our services, as well as for clients contacting us by phone / via email or in person and whose issue does not require the collection of personal data we process the following information: 1) municipality / district / region the client lives in, type of residence permit – the legal grounds are the provider’s legitimate interests (reporting). 2) in case of an email address, only the part before the “at” sign is being processed. Though the information is incomplete, it allows for the continuity of communication; the legal grounds being the fulfillment of a contractual obligation to provide a social service. The legal grounds for receiving personal data of a potential client before providing social services are the need to take certain measures before entering a contract to provide social services at the request of a data subject.
For clients whose situation requires the collection of personal data we process the following information: full name, phone number, email address, type of residence permit – the legal grounds being the fulfillment of a contractual obligation to provide a social service. The legal grounds for processing the information about municipality / district / region the client lives in and their country of origin are the provider’s legitimate interests (reporting). Depending on the client’s individual situation, other data essential for addressing this situation can be processed as well, such as home address, date of birth, health insurance provider, information about the client’s employer, personal identification number, names and dates of birth of their children under eighteen, etc. The legal grounds are the fulfillment of a contractual obligation to provide a social service.
The service Perspektiva (Perspective) always collects and processes clients’ personal data (there is a signed agreement). We process the following data: full name, home address, phone number, email address, type of residence permit (which gives information about their access to the labour market). The legal grounds for processing are the fulfillment of a contractual obligation to provide a social service.
If a client of one CIC social service starts using another one, a staff member of the second program will discuss with them the need for processing their personal data in accordance with the internal regulations of the second program.
Personal data is only processed for the necessary period of time, which for social services constitutes three years after the client contacted the CIC social service for the last time. When the three-year period is over, all records and documents that contain personal data are archived for 10 years. Processing, storage, and destruction of personal data is regulated by the CIC Operational Rules and Regulations (Provozní řád CIC).
When processing personal data, CIC uses its own tools for data storage (digital password-protected databases with personal authorization and locked physical archives). Personal data is protected against loss, theft, and misuse.
A client provides their personal data by completing a standard form of Consent to the processing of personal data. CIC does not ask for any copies of documents. CIC can accept copies of documents from a client if he/she wishes to share them and they are necessary for the collaboration. If documents contain sensitive data, the client is informed about its nature and asked to confirm whether they really wish to share them.
The clients who do not provide their personal data are entered in the CIC database as “anonymous”.
When a client emails to a social worker documents that contain personal data necessary for rendering social services, the social worker keeps them in their Outlook profile only, or in some cases in a digital folder for personal documentation. Documents containing personal data of a natural person who is not a CIC client will not be stored.
Only the staff members who signed the employee confidentiality agreement have access to clients’ personal data. An employee’s obligation to protect clients’ confidentiality stays valid after the termination of their employment with CIC. We do not pass personal data to third parties without an expressed consent of the client (except for the legal obligation to report certain crimes).
You have the right to obtain access to the personal data held about you, which means you can see the database and the folder with written notes and records about you.
You have the right to ask for personal data to be corrected or erased, and to request the restriction of the processing of your personal data in specific cases. You have the right to object to the processing of your personal data, the right to send your data to another controller and other rights under the General Data Protection Regulation (GRPR). If your personal data is being processed based on your expressed consent, you have the right to withdraw this consent at any time.
When processing personal data, we do not make decisions based on automated processing that could cause actions affecting your rights or legitimate interests.
To exercise you rights or make a request please contact the CIC Data Protection Officer at Pernerova 10/32, Prague 8. We will examine your request in a proper and timely manner and respond to it in accordance with the relevant provisions of the General Data Protection Regulation (GRPR). If you are not satisfied with the decision, you can contact the Office for Personal Data Protection (Pplk. Sochora 727/27, 170 00 Prague 7.)
The legal grounds for processing personal data for the purposes of other CIC projects are the following:
- The fulfillment of a contractual obligation.
- The consent of the individual concerned to the processing of their personal data.
The legitimate interests of the service provider (reporting statistics on the organization’s performance to show proper use of public funds; informing the clients of certain social services when based on our professional experience we believe they might be interested in other CIC activities).
The storage period is 10 years (longer in case of accreditation or specific requirements of a donor). The period of processing, retaining, and erasing of personal data is regulated by the CIC Operational Rules and Regulations (Provozní řád CIC).
For the courses of Czech As a Second Language we process the following personal data: full name, home address, contact details (email address, phone number). The legal grounds for data processing are the fulfillment of a contractual obligation and the provider’s legitimate interests.
For the retraining courses for teaching staff, Czech SL teachers, public officials, and social workers we process the following personal data: full name, home address, contact details (email address, phone number). When a certificate is being granted, the date and the place of birth and personal identification number is also provided (according to the requirements of an accreditation program). The legal grounds for data processing are the fulfillment of a contractual obligation and the provider’s legitimate interests.
For mentoring programs personal data is processed with the purpose of fulfillment of a contractual obligation. We process the following personal data of applicants: full name, home address, email address, phone number. The following information is optional: sex, age, information about your family, health issues, how long you have been living in the Czech Republic, your level of Czech, whether you have taken a Czech language course, your language of communication, employment in the country of origin, your plans in the Czech Republic, work or studies, interests, hobbies and needs – your personal request and preferences regarding your work with a volunteer.
For those interested in being a volunteer we process the following data: full name, home address, email address, phone number. The following information is optional: sex, age, information about family, health issues, language skills, work or studies, interests and hobbies, preferences regarding their work with a client.
For open public events we process the following personal data: full name and email address. The legal grounds are the consent of the individual concerned and the legitimate interests of the service provider.
For project activities (Velux, ESF, etc.) we process and store personal data following the specific requirements of a particular project and donor.
Before taking photos or recording videos featuring individual participants (not group pictures / videos) for promotion purposes or to demonstrate the results of a project, we ask them to sign a consent to the production and publication of these materials. The participants who do not wish to do so are never recorded. The legal grounds for processing a person’s image are always the consent of the person concerned. Names and other identification data is never published.
© Centrum pro integraci cizinců, 2019