Specific Privacy Statement ROMACT JOINT PROGRAMME (JP) website

Objective

The objective of this website is to observe as a dissemination and outreach activity towards increasing the visibility and impact of the ROMACT Joint Programme (ROMACT JP) in 2013, a joint initiative of the European Commission and the Council of Europe (CoE) seeking to assist mayors and municipal authorities in working together with local Roma communities to develop policies and public services that are inclusive of all, including Roma. It aims at serving as a one-stop-shop for practitioners in the respective policy change and capacity building and also for those members of the general public who are interested in the National Roma Integration Strategies.

It is hoped that the website will provide information about the phenomenon of Roma exclusion, ROMACT JP implementation in Member States and about initiatives, including legislation, targeted at the social integration of Roma communities. It will also provide a specific restricted access platform (Transnational Cooperation Platform), where practitioners and local authorities and other stakeholders can exchange best practice and information related to Roma inclusion, offer/search for partnership opportunities, allow contact exchanges for the purpose of the ROMACT JP.

In order to enable this, Local Administration Staff, Governmental Agency Staff, NGO mandated by local authority staff and other user groups will be given the option to register some personal information to a specific restricted access platform (Transnational Cooperation Platform), which will be kept privately by the CoE’s team responsible for the implementation of the programme. There will also be an option for practitioners to have their contact details published openly on the website for the general public to see.

This data collection will take place under the responsibility of the Special Representative of the Secretary General of the CoE for Roma Issues,acting as the Data Controller.

As this online service collects and further processes personal data, Secretary General’s Regulation of 17 April 1989 outlining a data protection system for personal data files in the Council of Europe, is applicable.

What personal information do we collect, for what purpose and through which technical means?

The CoE’s project team of ROMACT collects the personal data of the following data subjects for two different purposes.

Any Local Administration Staff (e.g. Government Agency Staff and staff of NGOs mandated by local authorities and involved in the development and implementation of policies and public services that are inclusive of all, including Roma) who want to obtain access to the restricted part of the website (Transnational Cooperation Platform) in order to communicate and share information will need to enter certain contact details as further described below. These details will then be checked by the Council of Europe, and once access is granted they will be posted as a user profile that will be viewable by other users within the restricted access area.

The Identification Data collected and further processed for the functioning of theTransnational Co-operation Platform restricted access area of the website are:

- the surname and first name of the registered users of this Platform,

- their profession and office department,

- their professional address including municipality and country,

- e-mail addresses and

- telephone number.

If website’s visitors (e.g. general public, officials from local, national and EU institutions, civil society etc.) have subscribed to receive the Newsletter by clicking on a link either in the issue which they received or on the Newsletter displayed on the ROMACT website, their personal data (name and email address) are collected and forming part of a mailing list in order to send the requested publication.

The collection of data is based on voluntary agreement by the data subjects who wish to make use of the options offered by the website.

Who has access to your information and to whom is it disclosed?

Access to your collected personal data is only granted through User Id/Password to a defined population of users who will typically be other practitioners / experts in the field who will have been granted identical access to theTransnational Cooperation Platform by the management team of ROMACT JP.

ROMACT National Teams Managers will also receive access to the data collected on theTransnational Cooperation Platform. ROMACT National Teams Managers are linked to the data controller by a legal data protection and confidentiality clause in their contract.

Data collected by the CoE on the ROMACT website and especially its Platform will be treated confidentially and used only by the management team of ROMACT JP and its contractors responsible for the receipt, processing of and response to all requests especially those dealing with the Newsletter.

With the aim of better distributing information on similar CoE activities, mailing lists composed by the names of the users of the Platform or broader mailing lists of persons subscribed to the Newsletter may be used in the future by the ROMACT JP Management Team for the purpose of contacting data subjects in the context of other ROMACT JP Management Team activities. In the same regard, they could also be shared with other services of the CoE following the written permission of the service managing the mailing list in question.

It may also be possible that the ROMACT JP Management Team resorts to a third party email marketing tool provided by either an EU or non-EU-based company as to synchronize email addresses where by the team can create, schedule, send and track the newsletter campaigns.

If data subjects do not agree with this, they may contact the Website Content’s Editor by using the Contact Information as mentioned in the Privacy statement.

The CoE will not share personal data with third parties for direct marketing purposes.

How do we protect and safeguard your information?

Your contact details are recorded in a secured and protected database hosted by an external company based in the EU.

This contractor is aware of the prime importance to the CoE of securing the hosted content in terms of confidentiality, integrity and data back-up, particularly in respect of the risks of physical or logical intrusion and is contractually committed to ensuring that your personal information is secure by putting in place and maintaining a security policy which meets the highest relevant security standards.

This contractor has i.a. guaranteed that no third party has access to the CoE’s data, in particular other clients of the contractor using the same Server.

It has also undertaken to:

- prevent physical access to the Server by any unauthorised third party and to keep the Server on premises which comply with professional standards, particularly in terms of electrical safety and protection from the risks of intrusion, fire or overheating.

- to put in place the necessary technical measures to protect the Hosted Content against computer viruses and against intrusions or attacks which might adversely affect the hosted content or its accessibility.

Inside the CoE the database can be accessed using a User Id/Password.

Access to the application is via a non-encrypted connection using the normal http protocol.

How long do we keep your data?

Personal data will be kept for as long as it is relevant for the functioning of the web site and especially its Platform. All personal data will be deleted immediately at the request of those concerned and if the website is stopped. It is probable that the aggregate data on groups (excluding individual-level data) will be kept for another two years for the purpose of the research analysis and reporting.

How can you verify, modify or delete your information?

In case you want to verify which personal data is stored on your behalf by the responsible Controller, have it modified, corrected or deleted, please contact the Controller by using the Contact Information below and by explicitly specifying your request.

Contact Information

In case you wish to verify which personal data is stored on your behalf by the responsible controller, have it modified, corrected, or deleted, or if you have questions regarding the website, or concerning any information processed in the context of the web site, or on your rights, feel free to contact the support team, operating under the responsibility of the Controller, using the following contact information:

Special Representative of the Secretary General of the CoE for Roma Issues

ROMACT Team: romact@coe.int

Recourse

Complaints, in case of conflict, can be addressed to the CoE’s Data Protection Commissioner

Ms Eva Souhrada-Kirchmayer

Data Protection Commissioner

DG I - Human Rights and Rule of Law

Data protection Unit

Council of Europe

F-67075 Strasbourg Cedex.

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