Privacy Policy of the “Emlékpontok – An Audio-visual Memory Collection” project and associated video library (excerpt)

2010. May 31.

The regulations shall apply to the Foundation for Research on East and Central European History and Society (hereinafter: Foundation), “Emlékpontok – Audio-visual Memory Collection” project and all persons involved with the project. This policy shall also apply to persons who, based on any form of authorization, are entitled to manage registered personal data, use systems containing such data, perform entry, processing, forwarding, or deletion of data, or perform technical operations or maintenance on the system.

The regulations shall apply to the Foundation for Research on East and Central European History and Society (hereinafter: Foundation), "Emlékpontok – Audio-visual Memory Collection" project and all persons involved with the project. This policy shall also apply to persons who, based on any form of authorization, are entitled to manage registered personal data, use systems containing such data, perform entry, processing, forwarding, or deletion of data, or perform technical operations or maintenance on the system.

1. The legal basis for the policy:

  • The Protection of Personal Data and Public Disclosure of Data Act of 1992. LXIII. Act (Privacy Act) and
  • The Public Documents, Public Archives, and Private Archives Protection Act of 1995. LXVI. (Archives Act).

2. This policy applies to treatment of data in the project of the Foundation called "Emlékpontok – Audio-visual Memory Collection".

3. The manager of the data covered by the policy is the Foundation (in relation to the archival material, hereinafter referred to as the Archive).

4. The Data Manager is responsible to the subjects and third parties for the management of personal data. The Data Manager also determines the goal of the data management and makes and implements or causes to be implemented through representatives, decisions related to the data management.

5. The purpose of the data management is the implementation of the project "Emlékpontok – Audio-visual Memory Collection", which serves the transfer of historical experiences through storytelling which was interrupted by the totalitarian regimes, to preserve the historical experiences of families and small communities, and support the inter-generational transfer of knowledge in such a way that ensures the subjects the right of self-determination. The project aims to achieve educational, social self-knowledge, and local history goals. It is not scientific research, but does make available for scientific research the resulting archival material (video library and related documentation).

6. In the application of the policy:

  • Personal data: any specific data that can be associated with a (identified or identifiable) natural person (hereinafter referred to as "subject") or the data from which conclusions can be drawn concerning the subject. The personal data preserves its quality as such as long as the relationship with the subject can be restored. A person is particularly considered to be identifiable if – directly or indirectly – the name, identification number, or one or more physical, physiological, mental, economic, cultural or social factors specific to the person can be identified

    The data may appear on paper, microfilm, magnetic, electronic or any other medium, and can include text, graphics, sound, image, video, or any other form of information or a combination thereof.

  • Specific data: data related to racial origin, national or ethnic origin, political opinion or party affiliation, religious or philosophical beliefs, membership in an advocacy organization, health condition, clinical addiction, sexual lifestyle, or criminal history;

  • Consent: the voluntary and explicit expression of the desire of the subject, based on adequate information, and which unmistakably gives consent to the management of personal data – within a defined range or covering specific operations – concerning him or her;

  • Data management: the process used, regardless of the operation or any set of operations carried out on the data, such as collection, recording, logging, organization, storage, alteration, use, transfer, disclosure, association or combination, securing, deleting or destroying as well as preventing further use of the data. The creation of photos, audio or video recordings, as well as recording personally identifiable physical features shall also be considered data management. Accessing or viewing personal data and viewing or listening to recordings containing personal data is also interpreted as data management by the rules of data protection;

  • Data processing: the performance of technical tasks related to the data management, if not carried out by the data manager, regardless of the methods or means of implementation or the location where performed;

  • Publication: Making the data publicly accessible to anyone.

7. Data source: personal communication, oral or written statements of the subject.

8. The legal basis for data management: the subject's voluntary and explicit consent, in writing, in which the subject agrees to the management of his or her personal and specific data by the Archive, to publish it on the World Wide Web or make it publicly available in any other towards the goal of inter-generational transfer of everyday historical experiences as set forth in point 5, or to contribute to educational or scientific research.
The subject shall be entitled to contribute to any of these above goals separately.

9. Data quality:
the Archive assumes responsibility that the personal data processed

  • is obtained and managed properly and lawfully,
  • is accurate and, if necessary, timely.

11. The data protection officer of the project of the Foundation called "Emlékpontok – Audio-visual Memory Collection" is responsible for the development of the data protection policy and compliance with changing regulations. The Data Protection Officer: Gábor Tallai, project manager of "Emlékpontok – Audio-visual Memory Collection".

11.1. The Data Protection Officer shall ensure that all persons subject to the policy understand and adhere to all aspects of the policy.

11.2. The Data Protection Officer shall ensure that the text of the policy is continuously accessible to all persons to which it applies. The Data Protection Officer shall carry out a review of the policy should it become necessary due to changes in the technical or legal environment, or in the activities of the Data Manager.

19. The Data Protection Officer is responsible for compliance with the data security requirements. In doing so, he or she must ensure that the system continues to meet the data security requirements.

20. The data collection shall take place in the form of video interviews.

21. Teachers participating in the project shall take part in data protection training as preparation for the data protection requirements of the project. They shall, by declaration, commit themselves to informing the students under their supervision of the professional requirements and data protection constraints of producing the memoir interviews. Participating teachers shall keep confidential personal information acquired according to the regulatory requirements. (Appendix 2)

22. Only students who are not incapable (14 years of age) may take part and who – in accordance with the rights of minors specified by international and domestic law – sign a declaration of their intention to participate in the program and that they are aware of and will comply with the data protection requirements. (Appendix 5)

23. During and after the interview, protection of personal information of the interviewee and of third persons must be observed. During the interview, specific information (such as religious belief, ethnicity, and political opinion) may also come to light. Both the head teacher and the Archive shall examine the legality of retaining this information. Data not legally recorded must be deleted prior to inclusion in the data store. Data of controversial legality shall be sealed, and during that time may only be viewed by those authorized by the Data Protection officer to assess its legality.

24. Subjects' rights:

  • Subjects may ask for information on how their personal information is handled.
  • Subjects may request copies of documents containing personal information.
  • Subjects may, at any time, request correction or deletion of their personal information.

25. The interviewee shall consent in writing to the data management (Appendix 1).

25.1. The subject providing information shall declare with what constraints on data management personal information is contributed. Specific indication shall be made as to whether the interview may be published on the website, thereby becoming public.

25.2. The subject may withdraw consent at any time, either during the production of the interview, immediately after, or later – up to the point of publication.

25.3. When the right to object is exercised following publication, the data must be deleted from the public database. Third persons on record (including in the video interviews) are also entitles to the right to object.

26. The published version of the interview must be made anonymous (e.g.: born: 1947, male, Bicske, farmer), unless the interviewee has consented to personal information being presented in the interview. Apart from the interview subject, the personal data of others in the archive may only be included as defined by the Archives Act. The interviewee shall consent with the understanding that when the recording is made public, he or she may be identifiable in absence of personally identifying information.

27. Data protection training. Teachers participating in the project shall take part in data protection training that shall be documented. The teachers conduct the data protection training for the students.

28.6. The project of the Foundation "Emlékpontok – Audio-visual Memory Collection" does not keep records about the online users.

Attachments:

Privacy statement (hu)





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