In accordance with the Regulation of 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (henceforth GDPR), the Act CXII of 2011 on Informational Self-Determination and Freedom of Information (henceforth Privacy Act), the Act CCIV of 2011 on National Higher Education (henceforth Nftv.), the Regulation on data protection, data processing as well as access to and publication of data of public interest of the University of Miskolc (henceforth Regulation), the Regulation on graduate tracking system of the University of Miskolc (henceforth DPR Regulation), the University of Miskolc (henceforth University) provides the following information on the data processing operations carried out by the ALUMNI/DPR system.
The purpose of the present data protection and data processing guide (henceforth Guide) is to provide information on the personal data processing carried out by the ALUMNI/DPR system of the University (henceforth tracking system) as well as the identity of the controller and the controller’s representative, legal basis for and purpose of personal data processing, duration of processing, identity and contact details of the controller, identity and contact details of the data protection officer, the rights and remedies available to the data subject.
Link to the tracking system: https://alumniworld.uni-miskolc.hu/
In the interpretation and application of this Guide, the definitions shall be governed by the GDPR and the Privacy Act.
In the event of a discrepancy between the terms and conditions of this Guide and the terms and conditions of use of the career tracking system published alongside this Guide, the provisions of this Guide shall apply.
II.1. The data controller and the data controller’s representative:
University of Miskolc
Institution identification number: FI87515
Telelphone: (36) 46 565-111
Represented by Prof. Dr. András Torma
A/4. Room 145
(36) 46 565-111/10-32
Dr. Csaba Deák
Room 132 Building A4
(36) 46 565-111/10-07, 10-91
II.2. Contact data protection officer
dr. Mário Certicky
Data protection officer
Legal and Administrative Department
Room 123 Building A4; (36) 46 565-111/1420
The tasks of the data protection officer are defined by the Data Processing and Data Protection Regulation in force in accordance with the GDPR.
III.1. Legal basis for data processing
(a)The legal basis for data processing at the University is the data processing authorisation for career tracking of alumni including doctoral students of the University pursuant to point (c) of Article 6 (1) of the GDPR or point (a) of Section 5 of the Privacy Act as well as point (g) of Section 18 (1) of the Act on National Higher Education.
(b)Data processing for the purposes of career tracking for current university students and current and former academic staff is based solely on consent pursuant to point (a) of Article 6(1) of the GDPR or point (b) of Article 5 of the Privacy Act.
(c)Data processing pursuant to points (a) and (b) in the career tracking system is based solely on the registration of current and former students, including doctoral students, and current and former acdemic staff (henceforth academic staff), during which the former student provides the personal data listed in point III.3. to the controller. In doing so, pursuant to point (a) of Article 6 (1) of the GDPR or point (b) of Article 5 of the Privacy Act the former student and the academic staff give consent to the processing of personal data are provided in accordance with point III.3.
III.2. Purpose of data processing
The purpose of data processing in the career tracking system is to follow the professional life path and university career of the current and former students, including doctoral students (henceforth collectively students), and to provide the opportunity for the students to be informed about the professional and other activities, scientific conferences organized by the University and to create a forum for students to communicate with each other.
The data controller also sends notifications directly to the data subject’s email address by the consent of the data subject on the events, professional conferences and other opportunities held at the University.
III.3. Range of data processed
For the proper functioning of the career tracking system, former students shall provide the following information:
a) during registration, the user shall provide the following information:
- given name
- unique user name
- unique password (which is at least 8 characters and contains at least one large and one small letter as well as one digit)
- email address (to which the registrant requests the sending of an electronic message to confirm the registration)
b) after successful registration, the user shall provide the following information:
- full name (surname and given name)
- gender (male/female)
- e-mail address*
- country of origin*
- country of residence
- residence (town)
- name of grant programme (if any, e.g. Erasmus+, Stipendium Hungaricum stb.)*
- duration spent in the programme*
- specialisation, faculty
- graduated (yes/no)*
- types of degree (BSc/MSc/PhD)*
- present place of work and position*
c) The user may provide further personal information in the career tracking system, such as:
- brief cv*
- ID picture*
- link to Facebook/LinkedIn profile*
- field of interest*
- education, development of personal competences
- innovation, science and research
- job opportunities
- society, culture, gastronomy
- skills and abilities*
- languages spoken*
- honours and recognitions*
With regard to personal data marked "*" in points (b) and (c), the user is entitled to decide whether it should be visible to other users. If the user does not select such an option, he or she shall be deemed to have refused to display his or her personal information. It shall be strictly prohibited to reveal and disclose personal data specified in point (a).
Personal data that is not marked with "*" are automatically revealed.
The processing of personal data provided by the user voluntarily (e.g. in a cv) pursuant to point (c) which is not expressly included in this Guide is considered to be lawful.
On entering the career tracking system, small text files, so called "Cookies" are placed on the device of the user of the career tracking system to identify him or her at login, and to ensure the best user experience and smooth operation of the system during the session. If the "cookies" are disabled, the system based on the use of "cookies" will not work properly. The data subject can disable the use of "cookies" in his or her browser settings.
III.5. Duration of data processing
The controller processes the personal data specified in point III.3. until the withdrawal of the data processing consent, or failing that, for 80 years from the termination of the student status.
University of Miskolc H-3515 Miskolc-Egyetemváros
Organisational units operating the career tracking system: IT Service Centre, Secretariat of the Vice Rector for Scientific and International Affairs
The University shall not and cannot transfer any personal data stored in the career tracking system to third parties, excluding compulsory data transfer or the request of the data subject.
The University does not engage a data processor for data procession in the career tracking system.
In its data processing, the University provides the data subjects unconditionally with the following rights to exercise:
1 The data subject may request information on and obtain access to the processing of personal data relating to him or her in a written request including by electronic means. At the request of the data subject, the data controller shall at any time provide information on the data relating to the data subject, their source, the purpose of the data processing, its legal basis, duration, the circumstances of the possible personal data breach, its effects and the measures taken to manage it, and - in case of transfer of the personal data of the data subject - on the legal basis and recipient of the transfer.
2 The data subject may request that his or her personal data be rectified without undue delay, if it contains inaccurate data and taking into account the purpose of data processing may request to have incomplete personal data completed.
3 The data subject may request the erasure of personal data concerning him or her without undue delay with the exception of compulsory data processing if any of the conditions set out in Article 17 of the GDPR exist.
4 The data subject may request the restriction of his or her personal data if any of the conditions set out in Article 18 of the GDPR exist.
5 The data subject shall have the right to receive the personal data concerning him or her provided by him or her to the University, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the University if the conditions set out in Article 20 of the GDPR exist.
6 If a student or participant in adult education has any comments or feels that the processing of his or her personal data is unlawful, he or she is invited to contact the data protection officer primarily (III.2). In case of infringement, the data subject may engage in legal proceedings (at his or her choice, the data subject may bring the infringement before the competent court of the place of residence or stay), as well as may contact the Hungarian National Authority for Data Protection and Freedom of Information (1125 Budapest, Szilágyi Erzsébet fasor 22/c, tel.: 06-1-391-1400, website: http://naih.hu; email address: firstname.lastname@example.org).
Requests to enforce the rights of the data subject must be submitted to the address of the data controller or to the e-mail address email@example.com. The controller shall provide written information in the shortest possible time, but no later than 25 days (within 15 days in case of objection).
Miskolc, 3 June 2019
Prof. Dr. András Torma
Dr. Csaba Deák