|The following statement explains our policy regarding the personal information we collect about you.|
eTwinning is an initiative of the European Union. It is part of the Comenius strand of the Lifelong Learning Programme (LLP). It is steered by the European Commission and implemented by its Executive Agency for Education, Audiovisual and Culture (EACEA).
The eTwinning platform is dedicated to respecting the privacy of its users. It provides a secured and safe environment for schools, teachers and pupils to collaborate and share with one another. The following statement outlines the policies by which the eTwinning platform collects, manages and uses the data provided by its users.
1. Online submission forms
As the eTwinning platform – which encompasses the eTwinning Portal, eTwinning Desktop, Project Diary, TwinSpace, Learning Lab and Groups – collects and further processes personal data, it is subject to Regulation (EC) 45/2001 of the European Parliament and of the Council of 18 December 2000 on the protection of individuals with regard to the processing of personal data by the European Community institutions and bodies and on the free movement of such data (OJ L8 of 12.1.2001, p. 1.).
The various tools present on the eTwinning Platform allow users to submit information in order to participate to eTwinning activities. When registering online and submitting other information, the data is collected and further processed for the purposes detailed hereafter under point 2. The relevant processing operations thereof are under the responsibility of the Data Controller, which is the head of the “Lifelong Learning: Comenius, ICT and Languages” unit at the EACEA.
2. What personal information do we collect, for what purpose and through which technical means?
(a) Personal information: The personal data collected on the eTwinning platform include:
- Registrant data: name, surname, role at school (if a teacher, the subjects taught), subjects for a potential project, language(s) of the potential project, age range of pupils involved in a potential project, email address and project idea(s).
- School data: official school name, address, town, email address, region and country.
- School leader’s data: name, surname, professional email address.
Optional data (which means that you are free to give your data or not)
- Registrant data: description, list of contacts within the Desktop, list of projects, availability to set up a Comenius School Partnership, eTwinning Prizes and other awards, picture of the registrant, photos and other information related to the usage of the eTwinning Desktop.
- School data: postal code, school number, telephone number, website.
(b) Other data: Registrants may also participate in project TwinSpaces, eTwinning Groups, Teachers’ Rooms and Learning Events and develop a Project Diary. In these cases, registrants can submit information for the purpose of participating in such initiatives. Access to such platforms is restricted to their registered members only.
The European Commission, EACEA and EUN Partnership AISBL (European Schoolnet), are not liable for any information or documents uploaded by third parties.
(c) Usage of data: The storage, processing and displaying of data is necessary to:
- allow registrants to find partners and set up projects;
- provide information about registrant activities within and outside eTwinning in order to enrich user and school profiles;
- provide information about the eTwinning projects;
- in general, allow eTwinning registrants to communicate and collaborate in the spirit of mutual trust and respect; and,
- allow and facilitate monitoring and research activities.
Aggregated statistics are collected regularly, including, but not limited to, the number of users during a specific period, the preferred subjects and/or countries chosen by teachers and account usage. In an effort to maximise user experience, the eTwinning Portal may keep track of user frequency, habits, preferences and settings.
Data related to users’ behaviour within the various areas of the eTwinning platform may be used only for the purpose to carry out research and monitoring by the EACEA, the European Commission, and authorities in charge of implementing eTwinning (e.g., Central Support Services (CSS) and National Support Services (NSS) and national or regional school authorities) and other third parties (for instance, duly authorised research centres and universities). All usage of data by the actors mentioned above must be communicated to the data controller, which reserves the right to deny authorisation to such use.
Data shall not be processed for any other purpose. The legal basis for these processing operations of personal data is listed under point 9.
(d) Technical information: Data is provided by the users themselves by submitting online forms in various areas of the eTwinning platform. The platform is run by a service provider (European Schoolnet) under a specific service contract with the EACEA. All data is collected in a database.
3. Who has access to your information and to whom is it disclosed?
For the purposes detailed above, access to the data is strictly limited to:
- eTwinning registrants (upon login on the Desktop): Full set of data except personal information, such as registrant’s email address and school leader’s data.
- EACEA, European Commission, CSS: full set of data.
- National or regional school authorities in charge of implementing eTwinning at national level (NSS): full set of data for users of their respective countries.
The transfer of specific data to other third parties (e.g., research centres and universities) can be permitted under specific authorisation of the Data Controller. Whenever possible, data will be processed in an anonymous way, especially if transferred to third parties for research purposes.
Personal data will never be used for marketing purposes.
Some data submitted by users will be displayed on the public area of the eTwinning Portal, which means that such data is freely accessible on the Internet. In particular:
- Registrant data: name, surname, role at school, (if teacher, subjects taught), subjects for a potential project, language(s) of the potential project, age range of pupils involved in a potential project and picture (if permission specifically given by the user).
- School data: official school name, town, region, country and picture of the school (if permission specifically given by the user).
- Project data: name, description, languages, age range of pupils, partner details, registration date and closing data (if available).
- Educational resources uploaded on the Resources Area which were granted public access by the creator.
Other data submitted by users on the eTwinning platform (e.g., messages in forums, online discussions and threads, files and pictures) will only be visible to other registered users related to the area of the Portal where they have been uploaded (e.g., eTwinning Groups, Learning Lab, TwinSpace, Project Diary). However, the administrator of such areas may decide to make part of the data publicly available. In this case, the registrant has the right to delete the information concerning the him/herself and the information related to his/her pupils.
4. How do we protect and safeguard your information?
The collected personal data and all related information are stored on secured servers of the service provider (European Schoolnet). The operations of the service provider’s computer centres contractually abide to the European Commission’s security directives and provisions established by the Directorate of Security for these kinds of servers and services.
5. How can you verify, modify or delete your information?
In case you wish to verify which personal data is stored on your behalf by the responsible controller, or have it modified or corrected, you may do this yourself online. The password you set during registration will allow you to log in and update your personal information or deactivate your profile. Users can ask to deactivate their profile at any time (please see below under point 6.).
6. How long do we keep your data?
Data related to statistics and research purposes is kept for the entire duration of eTwinning in an aggregated, anonymous format.
Data related to the profile of the user, as described in point 2, are kept for one year after the user’s last login. After one year from the last login, the user profile will automatically be set to inactive, i.e., no longer visible to other users or the outside world. A notification is sent to the user to inform her/him that her/his profile has been set to inactive and that he/she can re-activate his/her account by logging in again. A second and final reminder is sent after an additional year informing the user that, 2 years after her/his last login, his/her profile will be deactivated permanently. All personal information is then made anonymous.
In case users ask for the deactivation of their profile or the profile is automatically deactivated, no data will be visible to other eTwinning users. Data will be kept only in an anonymous form that does not allow for personal identification. If users with a deactivated profile want to continue using the platform, they will need to register again. The data remain solely for research and monitoring purposes at the disposal of EACEA, the European Commission, national or regional school authorities, authorities in charge of implementing eTwinning (Central and National Support Services) and other third parties (see point 3) under the authorisation of the Data Controller in an aggregated format.
7. Contact information
For any questions on your rights and the exercise of your rights related to the processing of personal data (like access and rectification of your personal data), please feel free to contact the Controller of the eTwinning platform at this address:
Head of Unit P1 – Lifelong Learning: Comenius, ICT and Languages
Executive Agency Education Audiovisual and Culture
Office: BOU2 02/57
Avenue du Bourget 1
In order to deactivate an account, please contact the Central Support Service at: email@example.com.
In case of conflict on any Personal Data Protection issue you can address yourself to the Controller at the above mentioned address and functional mailbox. You can also contact EACEA’s Data Protection Officer at the following email address: firstname.lastname@example.org
Should the conflict not be resolved by the Controller or the Data Protection Officer you may lodge a complaint with the European Data Protection Supervisor at any time: website – http://www.edps.europa.eu; email – email@example.com.
9. Legal basis
The main legal basis of the processing of personal data is:
(a) Article 4 of Commission Decision 2009/336/EC of 20 April 2009 setting up the Education, Audiovisual and Culture Executive Agency for the management of European Community action in the fields of education, audiovisual and culture in application of Council Regulation (EC) No 58/2003 (OJ L 101 of 21.4.2009, p. 21.);
(b) The Lifelong Learning Programme action (2007-2013) established by the Decision 1720/2006/EC of the Parliament and of the Council of 15 November 2006 (OJ L 327 of 24.11.2006, p. 45.).