Personal Data Protection Policy of the students of the Athens Conservatoire College of Music
The protection of all kinds of personal data of the students and their guardians is a primary concern of the Administration of the Athens Conservatoire College of Music and is ensured pursuant to the provisions of GDPR 2016/679 and the relevant Greek legislation in accordance with the following terms of the Personal Data Protection Policy.
Controller of the Personal Data Processing by means of the law, is the Athens Conservatoire College of Music having its headquarters in Athens, 17 – 19 Vas. Georgiou B’ Avenue and Rigillis street, hereinafter referred to as ACCM. For any question or query regarding the processing of their personal data and to exercise any of their rights listed below, the concerned students or the guardians of minor students can communicate through email to the following email address: collegeofmusic @ athensconservatoire.gr
2. The Personal Data that are subject to processing from ACCM
The Personal Data that are subject to processing during and in connection with the students’ study in ACCM, are the following:
a) Data requested directly from students or guardians of minor students at the time of enrollment, and, more particularly: name, surname, father’s name, mother’s name, date of birth, ID number and Tax Identification Number, full address, landline and / or mobile phone, email and also, in case the registrant applies for a deduction, scholarship or other financial aid, the most recent income tax return statement of the family issued from their competent Tax Office and / or the relevant certificate of family status. In the case of enrollment of a minor student, the above data are collected also for his guardians.
b) Data collected during the study and are related to the performance and progress of the students and, in particular, the syllabus and the individual courses they attend, their grades and other data related to their performances, their absences, awards, scholarships or other distinctions they may receive and, also, other specific comments related to their behavior and general evolution within the frame of ACCM.
c) The image (photos, videos) or/and any recordings and / or videotapes of the students during their studies in ACCM that are taken for archival reasons either in the context of the courses, or in the context of other educational and cultural activities in general, carried out under the responsibility of ACCM both inside and outside its premises (concerts, exams, seminars, etc.). Any use of the above material other than the archival use is completely excluded, unless there is a previously given special written consent of the student or the guardians of the minor student.
3. Forms and security of processing
Regarding the specific forms of processing by ACCM, the above-mentioned Personal Data are collected, registered and archived, stored in physical and electronic form, used, deleted and destructed.
The general processing of Personal Data is restricted within the headquarters of ACCM (17 – 19, Vas. Georgiou B’ Avenue).
The Personal Data will be available exclusively to the teaching, administrative and technical staff of ACCM, to specifically authorized external associates of ACCM (Legal representatives, photographers, graphic designers, typographers, etc.) as well as to public or judicial authorities, where required either by law (e.g. transfer of student registry to the competent Services of the Ministry of Education) or due to a possible exercise of the ACCM’s legal interest in judicial or other authorities. In any case, all types of employees or authorized associates of ACCM handling such data, undertake in writing the obligation of discretion and confidentiality.
ACCM ensure the protection of personal data from any leakage or loss by storing them in secure facilities with fully protected and controlled access.
3. Purpose and legality of the process
The processing of Personal Data is done exclusively for the following purposes :
a) For the organization, conduct and completion of the student’s study in execution of the contract for the provision of educational services concluded between a student or the guardian of a minor student and ACCM, in accordance with the terms of the Regulation of Operation of ACCM and the applicable provisions of the law for the operation of colleges of the Ministry of Education.
b) For the communication between the student or the guardians of a minor student and the Administration of ACCM on issues related to the student’s study, as well as to inform the student or the guardians of a minor student about the other educational and in general artistic – cultural activities of ACCM.
c) For the archival documentation and promotion of the actions of ACCM, as well as the creation of souvenir material regarding the student ‘s performance during his studies at ACCM. The above mentioned material may consist of photographs or videos taken with the special written consent of the student or, in the case of a minor student, his / her guardians, as well as other details of each student’s attendance such as name, his surname and father’s name, reference to any praise, awards, distinctions, participation in competitions, etc. Moreover, a selection from these data at the discretion of ACCM can be included in the annual Activity Reports of ACCM, where the total educational activity is recorded. The above processing of Personal Data is necessary for the complete fulfillment of the educational and cultural purposes of ACCM and, more particularly, for the updating of its archive as well as the evaluation of the quality of the services provided and their further future development and improvement. In any case, ACCM is committed to take all necessary measures for their protection from any unauthorized access, improper use, alteration, unauthorized promulgation, disclosure, loss, accidental or unlawful destruction or any other unlawful form of processing, while all the above strictly concern the proper educational function of ACCM and completely exclude any commercial use.
d) For the issuance of the required tax documents, in accordance with the current tax legislation.
e) For the collection of any debts as well as for other judicial uses and until the irrevocable, out-of-court or judicial settlement of the respective dispute.
4. Duration of the processing
ACCM will maintain the aforementioned Personal Data for as long as is necessary to achieve each of its above objectives. In any case, the determination of the necessary period of storage and processing in general is done in accordance with the deadlines set by law and the principles of minimization and necessity. Especially for the after the completion, or the in any way termination of the contract for the provision of educational services between ACCM and the student or the guardians of a minor student, ACCM will retain such personal data for the student record it maintains, in order to be able to issue in the future certificates of study, certificates of attendance, certificates of detailed grades, etc. whenever requested by the data subject. Finally, photos or videos taken with the special written consent of the student or, in the case of a minor student, his guardians, and posted on the website or social media of ACCM, can remain posted for up to five (5) years.
5. Personal data subject rights
The students or, in the case of minor students, their guardians, can at any time exercise the following rights either in writing at the secretariat of ACCM, and/or by sending an e-mail to email@example.com, submitting a relevant request which, in the case of a minor student, must be co-signed by both parents:
a) Right of Access, i.e. information by the Personal Data Controller of ACCM regarding the purpose of the processing, the categories of personal data concerned, duration and method of processing, etc.
b) Right to correction and completion of incomplete or inaccurate data (right to rectification)
c) Right to erasure (right to be forgotten)
d) Right to data portability, i.e the right to request and receive in machine readable format all the data given to ACCM by the respective beneficiary, or the right to request that they be forwarded to another Controller
e) Right to restriction of processing of data for as long as the examination of possible objections of the data subjects regarding their processing is pending
f) Right to object and revoke the processing of their data, in case the data subject considers that is affected in any way.
g) In special cases where the collection and processing of personal data requires additional explicit consent of the student or, in the case of a minor student, his guardians, as is the case e.g. for photographs, recordings or videotapes, the data subject may revoke its consent at any time with future validity, by submitting a relevant written statement to the secretariat of ACCM and / or by sending an email to firstname.lastname@example.org
All the above rights can be exercised in the manner mentioned in the beginning of the present paragraph, while the relevant requests will be examined by the Personal Data Controller of ACCM, who will weigh the alleged grounds of opposition in combination with the respective legal interest of ACCM to maintain such data. In the event of the exercise of any of the above rights by the data subject, ACCM will take all possible measures to satisfy the relevant request within one month from the submission and identification, informing the applicant in writing of the satisfaction of one or more of the above mentioned rights in accordance with GDPR 2016/679, or of the reasons that may prevent the exercise of these rights
Finally it is clarified that in any case, the beneficiaries of any kind reserve the right to file a complaint to the Personal Data Protection Authority, if they consider that their personal data or the data of their children are violated in any way.
The present update on ACCM’s student Personal Data Protection Policy is posted at the Student Services Office which is located at the headquarters of ACCM, on the electronic educational platform of ACCM (Virtual Learning Environment) as well as on its website (www.collegeofmusic.athensconservatoire.gr). To the above – mentioned points will be also posted any amendments or latest updates of the present Personal Data Protection Policy of which all beneficiaries must be informed by ACCM.