Personal Data Protection
Personal Data Protection
This document describes Fundació Esade’s data protection policy. The latter is based on the principles detailed in Regulation (EU) 2016/679 of the European Parliament and Council of 27th April, 2016 (General Data Protection Regulation). We fully assume the spirit of this European Regulation because it reinforces the rights of individuals and offers additional guarantees regarding the processing of their data. This objective coincides completely with our aim to continuously improve the services we provide. Below is a summary of the fundamental elements included in this data protection policy:
1. Who is responsible for processing personal data?
More info1. Who is responsible for processing personal data?2. What role does the Data Protection Delegate play?
More info2. What role does the Data Protection Delegate play?3. For what ends do we process data?
More info3. For what ends do we process data?4. How do we legally justify this data processing?
More info4. How do we legally justify this data processing?5. To whom do we cede data?
More info5. To whom do we cede data?6. How long do we store data?
More info6. How long do we store data?7. What rights do people have in terms of the personal data we process?
More info7. What rights do people have in terms of the personal data we process?8. How can the affected parties exercise and defend their rights?
More info8. How can the affected parties exercise and defend their rights?9. Specific data protection policies
More info9. Specific data protection policies1. Who is responsible for processing personal data?
The entity responsible for processing data is Fundació Esade (hereafter, “Esade”), with headquarters in Barcelona (Avinguda Pedralbes 60-62, 08034 – Barcelona), fiscal ID G-59716761, telephone number, (34) 932 806 162, and e-mail address, webmaster@esade.edu. Esade is duly registered in the Government of Catalonia’s Registry of Private Foundations under entry 510.
Esade is a higher-education centre integrated within Universitat Ramon Llull.
2. What role does the Data Protection Delegate play?
The Data Protection Delegate (DPD) is the person in charge of supervising that we comply with this data protection policy and ensuring that we process said personal data correctly and duly protect the affected parties. The DPD’s functions include receiving and answering questions, doubts, suggestions and complaints raised by people whose data we process. Affected parties can contact the DPD by writing to our postal address above, by calling the above phone number or by sending an e-mail to the following address: dpo@esade.edu.
3. For what ends, do we process data?
We process personal data in a proportional fashion, all the while taking into account the affected parties’ rights. This means that we process the appropriate, pertinent and limited data required for each specific situation and in due compliance with the explicit purposes for which data are gathered; that is, only the data required to carry out the educational services we provide in keeping with our mission. In some cases, we may require additional data, for example, to learn about people’s opinions or assessment of our services. In these cases, we process their responses statistically and in no way associate them to the personally identifiable data of those responding.
Esade processes personal data primarily to offer academic and extra-academic services, provide information about our activities and services and to establish commercial relations with our suppliers. Below are details on the key purposes for which we gather and process data.
Academic management
Contact
Personnel recruitment
Activity and service information
Client services
Information sent to our clients
Suppliers’ data
Register donations
Video surveillance
Website users
Other means of gathering data
How do we obtain personal data?
In the previous section we refer to some of the origins of the data we process. In most cases, the affected parties expressly provide us with their data, and we obtain them primarily through forms designed for this purpose. We also obtain data through open-door events, information sessions given on our campuses and fairs in which we inform about our programmes.
In terms of our relation with students, faculty and service providers, we gather other data which we incorporate into Esade systems.
A smaller amount of data may also originate from the competent public administrations in the higher-education area or from other academic institutions.
4. How do we legally justify this data processing?
The different types of data processing imply different legal justifications depending on their nature. We classify the different types of data processing in keeping with the legal bases established in Article 6.1 in the General Data Protection Regulation.
To provide educational services
To fulfil pre-contractual relations
To fulfil a contractual relation
To fulfil legal obligations
Based on consent
Legitimate interest
5. To whom do we cede data?
As a general norm, we will only cede data to comply with legal obligations. In the preceding sections we also describe how we cede our students’ data to provide them the educational services requested and those of our clients and suppliers to maintain the economic and commercial relations agreed on. We may also cede students’ data to other institutions within our group if duly authorised by said students.
Data are transferred outside of the European Union (international transfer) to manage students’ study abroad programmes and to respond to job offers from non-European firms. In both cases, said data are transferred with the students’ consent.
For some tasks, we also contract the services of companies or individuals based on their experience and specialisation. In some cases, these third parties may have access to personal data. In keeping with the General Data Protection Regulation, this access is not considered a type of data cession but, rather, a request to process said data. Esade only contracts the services of companies that guarantee they comply with this norm. When contracted, they duly recognise their confidentiality obligations, and we monitor them to ensure their compliance. Examples of the services contracted are data storage in external servers, providing computer assistance or legal, accounting and/or fiscal consulting.
6. How long do we store data?
The time we store data depends on different factors. The primary criterion is if the data are still necessary to fulfil the purposes for which they were originally gathered. The second criterion is to duly respond to any legal responsibility regarding Esade’s data processing and to comply with any legal requirements from public administrations and judicial bodies.
Consequently, we have to store data the time necessary to preserve their legal or informational value and to accredit our fulfilment of legal obligations. However, this time shall not exceed the time required for the purposes for which they are processed (“storage period” limitation in the General Data Protection Regulation). With respect to data accrediting the educational programmes students complete, we store said data permanently to preserve these students’ rights.
In specific cases, such as data included in accounting records and billing documents, fiscal norms require we store them until no longer legally required. The norms governing foundations require that we store some accounting-related data for ten years (in keeping with Law 10/2010, dated 28th April).
In the case of data processed solely based on the affected parties’ consent, we store said data until the affected parties revoke their consent.
Lastly, in the case of images obtained through our video-surveillance cameras, we store said images a maximum of one month. However, in case of incidents requiring they be stored longer, we shall preserve them the time necessary to facilitate the work of safety and security forces and judicial bodies.
The norms regulating the storage of public documents and the decisions issued by qualifying committees are a reference when deciding to store or eliminate data linked to providing public interest services.
7. What rights do people have in terms of the personal data we process?
As stipulated in the General Data Protection Regulation, people whose data we process have the following rights:
Know if their data are being processed
Be informed when data are gathered
Access their data
Rectify incorrect data
Request their elimination
Limit their processing
Portability
Oppose their processing
Not receive information
8. How can the affected parties exercise and defend their rights?
The affected parties can exercise the above-mentioned rights fast and easily through the following application form ARCO rights or writing to Esade at the address above or using any of the other means to contact us as indicated.
If the affected parties are not satisfied with this exercise of their rights, they may file a complaint with the Catalan Data Protection Authority by means of the forms or other channels available via its website (https://apdcat.gencat.cat/).
In all cases, whether to present complaints, clarify doubts or make suggestions, the affected parties may send an e-mail to the Data Protection Delegate via the following address: dpo@esade.edu
Specific data protection policies
Enrolment Process
Information Requests
Admissions Forms
Donations Forms