Data protection
Data Protection Statement
In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (“GDPR”), MTU Inclusio SICPD, hereinafter “Inclusio”, acts as the controller of the personal data relating to you that we process.
Therefore, we have compiled the data protection statement below, which is intended to provide you with information about our measures to ensure the confidential treatment and processing of your personal data.
This document concerns personal data as defined in Article 4 (1) of the GDPR, i.e. any information relating to an identified or identifiable natural person.
1. Collected personal information
Depending on your relationship with us and the context of our joint activities, the purposes of collecting your personal data will vary. However, the personal information we collect falls into, but is not limited to, the following categories:
• Identification data (eg name, address)
• Job related data (eg function, email address)
• Administrative data (eg educational qualification, identification number)
• Health data (eg disability)
• Biometric data (eg weight, photo)
• Data on the living environment (eg family aspects)
• Financial data (eg account number)
• Criminal records (eg previous convictions)
In addition, the performance of our activities requires the processing of special categories of personal data, such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, health data, sexual orientation of an individual.
However, it should be noted that the personal data of these special categories are collected and processed in strict accordance with the GDPR and the conditions of Article 9 (2) which permit their processing: the genetic data of these special categories in strict accordance with the GDPR and the conditions of Article 9 (2) which permit their processing, are collected and processed:
• The person concerned has consented to the processing of this data.
• Processing is necessary for the controller or data subject to exercise their rights under labor and social security law and to fulfill their obligations in this regard.
• Processing concerns personal data that the data subject has made public.
• The processing is necessary for public health or occupational medicine purposes, to assess the work capacity of an employee, for medical diagnosis, for health or social care or treatment, or to administer health or social systems and services.
In addition, and for certain specific data processing operations, we may avail ourselves of the exception described in Article 9(2)(d) for the processing of special categories of personal data, insofar as the processing is carried out by Inclusio in the course of its lawful activities and relates exclusively to members or former members of Inclusio or persons who have a permanent relationship with it in connection with these purposes.
2. Purpose of data processing
Generally, your data will be processed for the basic and general purposes described below:
• Management of the application process for admission, including admission to the hostel, professional integration seminars, educational institutions and kindergartens
• Daily administration of people using the services of Inclusio, including the development of life concepts for users, maintenance of school documents, organization of transportation of people with disabilities
• Maintenance of patient records (which are also subject to medical secrecy), socio-psychological and socio-pedagogical assistance cards, biographies and therapeutic documentation,
• Driving Inclusio vehicles through geolocation,
• Manage access to various Inclusio locations,
• Administrative, accounting, commercial management, billing and IT administration,
• Promoting the activities of Inclusio and its social goals,
3. How do we collect your data?
Personal data processed by Inclusio is mainly collected in the following ways:
• Standard paper or electronic forms that you fill out (via email, phone, and face-to-face),
• Photo and video for medical examinations.
4. Legal basis for the processing of data concerning you
All purposes of the data processing described in paragraph 2 are based on the following legal bases in accordance with Article 6 of the GDPR:
• Pre-contractual measures or execution of contracts
• Fulfillment of legal obligations
• Legitimate interests
• Consent
• Vital Interests
5. Sharing and transferring your personal data
5.1. Processor of your personal data
To achieve our goals, we select only those processors that they offer sufficient guarantees that the appropriate technical and organizational measures will be implemented in such a way that the processing is carried out in accordance with the requirements of this regulation and guarantees the protection of the rights of the data subject.
5.2. Recipients of your personal data
We may share your personal data with different categories of recipients. These include:
• Public institutions and authorities (eg responsible ministries)
• Control authorities (for example, in the field of security)
• Services (eg banks, insurance companies)
• Foundations, associations, or other non-profit organizations (such as other care institutions)
• Health care workers (eg hospitals)
• Lawyers, auditors and certified public accountants
• Subcontractors (for example, in the field of long-term care insurance, nursing and therapy)
• Other third parties that Inclusio is interested in working with
We guarantee that we do not sell your personal data to other parties for marketing purposes or for any other commercial activity.
6. Shelf life
We reserve the right to store your personal data for as long as the purpose of processing requires it. The retention period may be based on our legitimate interests or the performance of a contract to which we are bound.
In addition, the period of storage of your personal data complies with the periods permitted by law.
7. Your rights
The GDPR allows you to exercise various rights in relation to your personal data, which are described in Articles 12-23 of the GDPR. Therefore, we are committed to considering all requests from you. However, it is important to note that there are situations where we are unable to comply with your request (for example, where the legal basis for the processing does not allow the exercise of a certain right). Below you will find a brief description of your rights.
If you would like to make a request, we refer you to Section 8. Contact”.
7.1. Right to provide information
The right to information allows you to ask us for information about what personal data we hold about you and to request that we transfer that data to you for content verification purposes.
7.2. Right to Correction
The Right to Correction allows you to request that inaccurate or incomplete information about you be corrected. This helps prevent the use or dissemination of inaccurate data about you.
7.3. Right to erasure (“Right to be forgotten”)
The right to erasure allows you to request that we delete your personal data.
7.4. Right to restriction of processing
The right to restrict processing allows you to request that we temporarily suspend the use of some of your personal data.
7.5. Right to data portability
The right to portability allows you to retrieve the personal data you have provided to us in a machine-readable format. Thus, you can store this transmitted data elsewhere or transfer it between different systems and from Inclusio to another responsible person in order to reuse it for other purposes.
7.6. Right to object
The right to object allows you to object to the use of personal data at any time.
7.7. Right to withdraw consent
Any person who consents to certain data processing has the right to withdraw their consent at any time. This withdrawal of consent does not affect the lawfulness of processing based on consent given before the withdrawal.
7.8. Right not to be subject to a decision based solely on automated processing, including profiling
You have the right to object to a decision based solely on automated processing. The collection and analysis of your activities allows you to create profiles that serve to better classify your personality and your behavior. Sometimes decisions are made automatically based on such a profile, without human intervention.
7.9. Right to lodge a complaint with the national supervisory authority
If your requests are not dealt with satisfactorily, you have the right to file a complaint with the Data Protection Inspectorate.
8. Contact
If you have any questions about this statement or any other data protection related topic, you can contact our Data Protection Officer using the contact details below:
MTU Inclusio SICPD
Kentmanni 6, 10141
Tel.: (+372) 567 1111 7
E-mail: report@inclusive-policy.eu
9. Revision of this Statement
We review this statement regularly and keep it up to date. Last revised date: June 1, 2023