1
Data Processing Notice
to the processing of personal data by the Moholy-Nagy University of Art and Design Budapest
('MOME') in the framework of the University Life Platform.
The personal data provided will be processed and stored based on the
voluntary consent
of the data
subject, in full compliance with the data protection regulations in force at any given time, in
particular Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).
Data Subject
: a natural person that is identified or identifiable based on any information.
In this case, the
person making the declaration.
Personal data
: means any information relating to an identified or identifiable natural person (‘data
subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number, location data, an online identifier or to
one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person.
Controller
: The natural or legal person or organisation without legal personality which, alone or jointly
with others, determines the purposes for which the data are to be processed, takes and implements the
decisions concerning the processing (including the means used) or has the data processed with the
processor, within the limits set by law or by a legally binding act of the European Union.
Processing
: means any operation or set of operations which is performed on personal data or on sets of
personal data, whether or not by automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission,
dissemination or otherwise making available, alignment or combination, restriction, erasure or
destruction.
Consent
of the Data Subject
:
means any freely given, specific, informed and unambiguous indication of
the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies
agreement to the processing of personal data relating to him or her.
On the protection of personal data
The Controller shall respect the protection of personal data and, in compliance with the applicable
legislation in force at all times, ensure the processing and retention of such data made available to it. The
Controller
shall use the personal data only for the purposes indicated, shall not merge them with its
databases from other sources, shall not disclose the personal data processed to third parties without the
express consent of the Data Subject,
unless expressly provided for by law
, and shall use all reasonable
efforts to protect such data.
Name and contact data of the controller:
•
name: Moholy-Nagy University of Art and Design Budapest;
•
registered office: 1121 Budapest, Zugligeti út 9-25.;
•
e-mail: info@mome.hu;
•
phone: + 36 1/ 392-1180;
•
Controller’s representatives: József Fülöp Rector; Réka Matheidesz Chancellor
•
data protection officer: Dr. Márk Kovács
•
e-mail: jog@mome.hu
2
Legal basis of processing:
•
for all personal data processed: the data subject’s voluntary consent [Article 6(1)(a)
of the GDPR]. Information on the legal basis for the processing of each data item is set out in
Annex 1, column C.
By signing the Consent Form, the following personal data will be processed:
•
The list of data processed is set out in Annex 1, column A.
Purpose of processing:
•
The purpose of the processing, per data processed, is set out in Annex 1, column B.
Data retention time:
•
The data retention time, per data processed, is set out in Annex 1, column D.
Data accessibility:
•
The data can only be accessed by the relevant MOME staff and will be treated
confidentially by MOME. Information on the accessibility of data, per data processed,
is set out in Annex 1, column E.
Data storage and data security:
•
Information on data storage, per data processed, is set out in Annex 1, column F.
The data subject’s rights in relation to the processing of his or her personal data:
No automated decision-making or profiling is carried out on the basis of the data subject’s data.
Protection of your personal data: your data stored electronically may only be accessed by duly
authorised staff for the purposes set out in the Data Processing Notice.
The Data Subject may exercise his or her rights set out in this Section in
relation to personal data
processing
at any of the contact details of the Controller specified above, as follows:
•
Right to withdraw consent (Article 7 of the GDPR): if the processing of certain data is based
on your consent, you can withdraw your consent at any time. The withdrawal of consent
shall not affect the lawfulness of the processing performed on the basis of the consent.
•
Right of access (Article 15 of the GDPR): In particular, you may access your personal data
processed by the University, you may obtain information on the manner and circumstances
of such processing, and you may request a copy of the data.
•
Right to data portability (Article 20 of the GDPR):
You have the right to request a copy of
your personal data and send it to other organisations, or possibly to request the University to
transfer these data, if the processing is based on consent or a contract or is automated. The
request may be refused if the processing of the data is in the public interest.
•
Right to rectification (Article 16 of the GDPR): You may request the rectification of
inaccurate personal data processed by the University without undue delay and the
completion of incomplete personal data. The University will then check the accuracy of the
data and, depending on the result, correct it. In such a case, the University will not only
correct the data in its own records, but will also forward your request to the persons and
organisations with whom it has shared the data, and who are reasonably accessible to it.
3
•
Right to erasure (Article 17 of the GDPR): You may request the erasure of your personal data
from the University’s records if:
o
the purpose of the processing no longer exists and there is no longer a need to
process the data;
o
the processing of your data is unlawful, for example if the University processes the
data without a proper legal basis;
o
your data must be erased in order to comply with a legal requirement;
•
Right of restriction (Article 18 of the GDPR): You have the right to ask the University to
restrict the processing of your data. In such a case, your data will be blocked, after which any
processing operation (other than storage) may only be carried out with your consent. The
restriction may be lifted if the use of the data in question is necessary for the establishment,
exercise or defence of a legal claim or for the protection of the rights of others or in the public
interest of the Union or of a Member State. You will always be informed when the restriction
is lifted. The University will forward your request for restriction to the persons and
organisations with whom it has shared the data, and who are reasonably accessible to it. The
right of restriction may be exercised in the following cases:
o
If you contest the accuracy of the personal data, the restriction will apply for as long
as the University verifies the accuracy of the personal data;
o
the processing of the relevant data is unlawful, but you object to the erasure of the
data for any reason;
o
the University no longer needs your data, but you need it for purpose of
establishment, exercise or defence of a legal claim;
•
Right of redress (Chapter VIII of the GDPR): if you believe that the University has infringed
your rights to your personal data, you may ask the University to remedy your rights, you may
lodge a complaint with the Hungarian National Authority for Data Protection and Freedom of
Information (hereinafter as: the
Authority)
or take your case to court.
The registered office of the Authority: 1055 Budapest, Falk Miksa utca 9-11.
Postal address of the Authority: 1374 Budapest, Pf. 603.
The telephone number of the Authority: +36 1 391 1400
The fax number of the Authority: +36 1 391 1410
Email of the Authority: ugyfelszolgalat@naih.hu
Website of the Authority: www.naih.hu
If you believe that we are not acting lawfully in the processing of your personal data, please first
communicate your observations or requests to us, acting as the Controller,
using one of the contact
details listed above
, in order to enable us to process and handle your observation as quickly and
efficiently as possible.
How to submit a data protection request
You can submit your requests to exercise your data protection rights electronically to
When submitting an application, the applicant must ensure that his/her identity is clearly identifiable
and provide at least the following information:
•
surname and first name;
•
date of birth;
•
tax ID;
The University will inform you of the action taken in response to your request as soon as possible
after receiving it, but no later than 30 days after receipt of the request. This deadline may be
4
extended once, by up to 60 days, in view of the complexity of the request or the number of requests;
the University will officially notify you of this within 30 days of receiving the request.
Safeguards and security measures
The University shall implement appropriate technical and organisational measures for ensuring that,
by default, only personal data which are necessary for each specific purpose of the processing are
processed. That obligation applies to the amount of personal data collected, the extent of their
processing, the period of their storage and their accessibility.
In addition to the above, the University shall protect the data against unauthorised access, alteration,
disclosure, transmission, publication, deletion or destruction, as well as accidental destruction or
damage, in particular by additional physical (electronic asset protection systems at the University’s
premises), logical (password protection, firewall, access control) and administrative (dedicated
policies for asset protection systems, staff training on data protection and information security)
measures proportionate to the risk of data processing.
Review of the data protection notice
The University will review the data protection notice regularly and will ensure that it is updated as
necessary. The University will inform data subjects of any changes to the data processing notice. In
determining how to provide the information, the University will take into account considerations
such as the significance of the change or the scope of the persons and data affected by the change.
Annex 1
| A | B | C | D | E | F |
|---|---|---|---|---|---|
| data item name | purpose of data processing | legal basis of data processing | data retention time | data accessibility | storage of data |
| User persona (student/employee), active status | Access control, regulating access to institutional services, ensuring organisational functioning | the data subject's consent (Article 6(1)(a) of the GDPR) | During the period of the legal relationship, + 3 months | MOME staff in charge (HR, Department of Studies, system administrators), no data transfer takes place | On MOME servers, institutional databases |
| Calendar event data (data synchronised from Microsoft Graph API) | Providing calendar functionality, displaying events, improving user experience | the data subject's consent (Article 6(1)(a) of the GDPR) | Temporarily cached according to technical retention period (max 2 days per event) | MOME IT staff in charge, no data transfer takes place | In cache |
| Administrator change log (log) | Ensuring transparency, traceability, system security | the data subject's consent (Article 6(1)(a) of the GDPR) | Permanent (max 10 years) | MOME staff in charge (IT, system administrators), no data transfer takes place | On the MOME server, databases |
| User preferences (saved tags, articles, events) | Displaying personalised content, improving user experience | the data subject's consent (Article 6(1)(a) of the GDPR) | Until the user account is terminated or deleted | MOME staff in charge, no data transfer takes place | On the MOME server, databases |
| Device and technical analytics (Application instance identifier (unique per installation); Application version; Device brand; Device type/model; Device category (mobile/tablet); Operating system (iOS/Android); Operating system version; Language setting (device language); Screen resolution) | Ensuring application functionality, measuring its performance, identifying and fixing bugs, and improving service quality and user experience by analysing technical and device usage data. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Geographic analytics (derived from IP address, IP is not stored): country, city, continent, region | Analysing geographical patterns of application usage, measuring the spatial performance of the service, optimising feature availability and improving user experience through the evaluation of derived (not stored) IP-based location data. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Usage Events: first_open - first open (first launch of the application after installation) session_start - start of session user_engagement - user activity (the application is in the foreground) screen_view - screen view (screen change) app_update - event after application update os_update - event after operating system update app_remove - removal of the app (Android only) app_clear_data - erasure of app data (by user, Android only) | Analysing application usage patterns, understanding user behaviour, measuring feature effectiveness, identifying errors/performance problems, and improving and optimising the service based on usage events. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Push notifications | To receive notifications, the application stores a push token to identify the device. Notifications are delivered via the Expo service and can be turned off in device settings. | the data subject's consent (Article 6(1)(a) of the GDPR) | Permanent (max 10 years) | MOME IT staff in charge, no data transfer takes place | On the MOME server, databases |
| Search analytics | Analytics examines the use of the search function: what terms users are searching for, broken down by persona, which searches return results, which searches do not return results. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Platform navigation analytics | Analytics show which external platforms users navigate to from the app and which page tiles they click on. It aims to improve the menu system and navigation, optimising access to institutional platforms. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Onboarding process analytics | Analytics show how users are customising the app: how many users skip onboarding, how many users choose at least one tag (successful onboarding). The aim is to measure the effectiveness of the onboarding process and improve the user experience. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |
| Analysing admin activity | Analytics examine: which admins publish content, with what frequency, what are the tags they use, how many events or articles are uploaded. It aims to improve the transparency of administrative processes and to examine content upload activity. | the data subject's consent (Article 6(1)(a) of the GDPR) | automatically deleted after 14 months | MOME IT staff in charge, no data transfer takes place | Stored on Google servers (pursuant to US, EU data protection agreements) |