GDPR Information Clause

Pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, General Data Protection Regulation – GDPR, and Regulation (EU) 2018/1725, we hereby inform you that:

§1 Entities processing data

1. The Data Administrator is the European Commission, Directorate-General for Education, Youth, Sport and Culture – DG EAC. https://commission.europa.eu/about/contact_en
2. The data Processor is the Spanish National Agency for the Erasmus+ Programme in the field of Education and Training, acting as the National Agency responsible for the Erasmus+ Programme in Spain.
3. The sub-processor is Colegio Virgen de La Rosa, Burgos, Spain, acting as the beneficiary and project coordinator of the grant agreement for the project 2025-1-ES01-KA220-SCH-000358858 “BrightMind: Active Recall for Key Competences and Classroom Inclusion”.
4. Project partners may also process personal data only for the purposes of project implementation, reporting, communication, dissemination and evaluation, in line with their project roles.

§2. Categories of data

1. Identification and contact data: first name, last name, date of birth, institutional affiliation, e-mail address, telephone number;
2. Professional and organisational data: information related to participation in training activities, learning outcomes, evaluations, and records of participation in project events;
3. Image data: photographs and video or audio recordings documenting participation in project activities, within the scope of the consents granted;
4. Special categories of data: information concerning health, disability, dietary requirements or other accessibility needs, processed only to the extent necessary to ensure safety and accessibility;

§3. Data Source

1. Data is obtained directly from project participants or partners involved in its implementation, as well as through IT tools used as part of project activities.

§4. Purposes and basis of processing

1. Project implementation and accountability of the project 2025-1-ES01-KA220-SCH-000358858 “BrightMind: Active Recall for Key Competences and Classroom Inclusion”, lasting from 01/10/2025 to 30/09/2027, including recruitment, organisation of educational and training activities, monitoring, evaluation, reporting, auditing, and archiving – pursuant to Article 6(1)(c) and (e) of the GDPR in conjunction with the applicable EU regulations for the Erasmus+ Programme and national rules for the implementation of EU-funded projects.

Specifically:

a. Ensuring the safety and accessibility of participants, including educational adaptations;

b. Organisational and substantive communication with participants;

c. Promotional and informational activities, including image publication, within the scope of separate consent and in line with applicable copyright and personal data protection rules;

d. Establishing, pursuing, or defending legal claims, and archiving evidence.

§5. Voluntary Provision of Data

1. Providing personal data is voluntary but necessary to participate in the project. Refusal to provide data makes participation impossible. Consent for the use of image is separate and voluntary.
2. Data are stored for the duration of the project and for the legally required archiving period, not shorter than 5 years after the project’s completion. In the case of proceedings or claims, data will be retained until their final conclusion and the expiry of limitation periods.
3. Data are not transferred outside the European Economic Area.
4. Data subjects have the right to: access their data, rectify them, erase them, unless exceptions under Article 17(3) GDPR apply, restrict processing, transfer data where processing is based on a contract and carried out automatically, object under Article 21 GDPR, and lodge a complaint with the competent national data protection authority.
5. A data subject may object at any time to data processing based on Article 6(1)(e) or (f) GDPR for reasons related to their particular situation. In case of an objection to data processing for informational and promotional purposes, the project partnership will cease processing the data for those purposes.
6. Data are not used for automated decision-making or profiling that produces legal effects. Analysis of activity within digital systems is used solely for the organisation of the educational process.

§6. Security Measures & Final provisions

1. The BrightMind project partnership applies appropriate technical and organisational measures, including access control, encryption where applicable, pseudonymisation where applicable, data backups, supervision of IT providers, and staff awareness of personal data protection rules.
2. For underage participants, consent from a legal guardian is required for participation in the project; publication of a participant’s image requires separate consent. Lack of consent for image publication does not exclude participation.
3. Requests regarding personal data should be sent via email to the project coordinator:

Colegio Virgen de La Rosa

Email: directorvrosa@cajadeburgos.com

Contact person: Altamira Alicia López Gallego
Email: altamiralopez@cajadeburgos.com

Responses are provided within a reasonable period and in line with the applicable GDPR requirements.